SF Express (Europe) Co. Ltd. Business Partner Privacy Policy

This Notice last changed on November 30, 2020.

Who we are

SF Express (Europe) Co., Ltd., S.F. Express Co., Ltd., and SF Technology Co. Ltd. (“SF”, “we” or “us”) always respect your privacy and value the trust you place in us when you share your personal information with us.

This Privacy Notice ("Notice") sets out how we collect, hold, use, disclose and otherwise process your personal information, why and with what legal reasoning we process it, with whom and for what purposes we share it, the rights to which you may be entitled and your choices about our use of your personal information. This Notice applies to our processing of your personal information where such processing is subject to the data protection laws applicable in the UK (including the General Data Protection Regulation). This Notice covers our use of personal information when we provide products and/or services to you or your organisation, when you use our  official website or IBS website  (the "Website"), our mobile applications (if applicable) and any other channel or mobile feature that we operate, when you place an order with us, or are otherwise in contact with us and when you purchase services and interact with us offline (collectively, the "Services"). If any of these apply to you, please read this Notice carefully. SF will display this Notice or the links to this Notice at the Website (including when you are placing your orders).

When we refer to "you" in this Notice, this includes you and/or your organisation.

SF Express (Europe) Co., Ltd., S.F. Express Co., Ltd., and SF Technology Co. Ltd. are the data controllers in respect of your personal information that they process. Their contact details are set out in Annex 1 of this Notice.

SF Express (Europe) Co., Ltd. and S.F. Express Co., Ltd. are joint data controllers in respect of the processing activities that they carry out when providing our services to you. For more details please see Annex 2 of this Notice.

Children

We do not knowingly collect information from children under the age of 18 and our Services are not aimed at them. If you are under the age of 18, you may not submit any personal information to us or register for the Services and if you want to use our Services, please rely on a parent or guardian to assist you.

If you – as a person with parental responsibility over the child – find out that your child has provided us with personal information without your approval please contact us and we will remove the personal information if required.

Data collection and usage

Legal bases for data processing

Ways we collect your data and sources of data

Legal and other requirements

How long we keep your information

Information we share

Where your information will be held

Your rights

Security

Links to third party websites

Changes to this notice

How to contact us

 

1. Data collection and usage

We will collect store and use your personal information:

    a) to conduct our business;

    b) to allow access to our Website, register / subscribe / buy / use our Services;

    c) to allow access to and use of our mobile applications (where available) ("Apps");

    d) to meet our legal obligations;

    e) to fulfil any purpose we make known to you when we collect your personal information; and

    f) to fulfil other purposes set out in more detail in this section.

We have identified below the types of information we may collect or receive, how we will use it and why we will use it.

    a) Account registration: in order to complete creating an account on our Website, we will ask you to provide the following information (hereinafter collectively referred to as “Account Information”): your mobile phone number, email address, account name and account password. We will verify your identity by sending a verification code through email.

    b) Logistics services (including customs clearance): when you place a shipping order or your information is provided to us because you are a receiver of a shipping that is placed with us, SF (or its authorized business partner, where applicable) will collect your information for the following purposes: (i) placing the shipment order; (ii) generating parcel labels; (iii) generating pro forma invoices; (iv) tracking the parcel as it travels to the recipient; (v) taking care of outbound customs clearance; (vi) taking care of inbound customs clearance in China; and (vii) delivering the shipment in China. The personal information we will process for these purposes include the following:

        • names, addresses and contact information of the shipper and the receiver;

        • shipment information (“Waybill Information”) (we use this information in order to submit an order, generate a logistics waybill, pick up, sort out, store and transport the shipment, conduct export or import customs clearance, and deliver the shipment);

        • where permitted or required by law, collect your identity documents to verify your identity and conduct export or import customs declaration;

        • name, contact information and any other information that you may provide to us when you contact us for a complaint or a request (note that if you call our call centre or otherwise reach us by telephone, we may record the conversations in order to manage and/or avoid any potential disputes); and

        • if we have been provided with incorrect or incomplete address for delivery, we may, subject to applicable law, complement and/or correct such address information by using your previous Waybill Information to avoid repetitive confirmation of the address with the shipper/receiver and guarantee the efficiency of delivery (so that the risk of you suffering loss due to mis- and/or delayed delivery is minimised and you can enjoy better service experience).

    c) Payment details: If you would like to receive an invoice for our Services, we will also collect the following information: invoice title, taxpayer ID, recipient’s email address, and any additional information provided according to your invoicing demand such as buyer’s information.

    d) Send messages: We will collect your device information so that we can send you shipment routing, payment status, coupons and sales promotions. You may enable “Do Not Disturb” in “Settings” on your mobile phone or other devices or, where applicable, in APP or the official WeChat account.

    e) Customer service and after-sale service: Our customer service and after-sale service representatives may use your Account Information and Waybill Information. This is to guarantee your account safety. Our call centre and online customer service representatives will use your Account Information and Waybill Information to verify your identity. When you want us to provide you with customer service and/or after-sale service with respect to the Services we provide to you, we will ask for your Waybill Information and shipment routing information. You may also be asked to provide additional information if needed to respond to your query.

    f) Surveys: Where we are carrying out surveys, we may collect information that you have submitted to us if you choose to participate in our survey (including the contact person’s name, company name, contact phone number, email address, your inquiry information submitted by you in “Cooperation Inquiry” on the official website of S.F.).

    g) Improve our products or services: Based on your Account Information and Waybill Information, we may create a user profile to provide you with personalized services and send information on Services that you may be interested in. Where applicable we may combine the information we collect from your various devices to improve our service offering (e.g. to ensure that Services that are offered to you from various devices are consistent and/or complimentary with each other). In order to provide you with personalized services and improve our Services (including improving the performance of express collection / delivery and overall customer experience), we may, where permitted by applicable law, also combine and carry out data analytics on the information we collect about you (i) through your use of our Services; or (ii) from publicly available sources (such as official government websites (e.g. the industry and commerce department, the transportation department, taxation department, courts)).

    h) Security: In order to ensure the security of our systems (e.g. to prevent any phishing attack, protect your account secure), where permitted and/or required by applicable law, we may process your browser information, URL, Waybill Information, information about the software or device you use. We also collect information about you through our security systems (such as CCTV) when you visit our premises.

    i) Direct marketing: In order to promote our Services, and to the extent permitted by applicable law, we may carry out direct marketing including sending ads and other commercial information that you or your organisation may be interested in. For this purpose, we will process your name, your organisation and contact details such as your corporate e-mail address.

    j) Anonymisation: Subject to applicable laws, we may anonymise, aggregate or otherwise de-identify your personal information (in a way that it is no longer possible to identify you) to carry out data analytics, statistical studies and to help us understand how we can improve our Services.

 

2. Legal bases for data processing

For the processing of your personal information, SF needs a lawful basis. The lawful basis for our processing depends on the purposes of the processing. Whenever we collect or otherwise process your personal information, we do so on the following legal bases:

    a) Where required by law, your consent to such collection and processing (for example, we may need your consent in order to process your personal information for direct marketing activities or when using technology such as cookies);

    b) Out of necessity for the performance of a contract with you, such as your agreement to our Terms of Use and other agreements;

    c) For the purposes of our legitimate business interests provided that, in each circumstance, we will weigh the necessity of our processing for the purpose against your privacy and confidentiality interests, including taking into account your reasonable expectations, the impact of processing, and any safeguards which are or could be put in place. In all circumstances, we will limit such processing for our legitimate business interest to what is necessary for its purposes. Where we process personal information on the basis that the processing is necessary for the purposes of our legitimate business interests, such interests include:

        a. the promotion of our Services, improvement of your experience when interacting with us;

        b. product development and enhancement, where the processing enables us to enhance, modify, personalize, or otherwise improve our Services and communications for the benefit of our customers, and to better understand how people interact with our Services;

        c. intra-organization transfers for administrative and other legitimate business purposes;

        d. fraud detection and prevention;

        e. defence or establishment of legal claims;

        f. enhancement of our, our employees and third parties' (such as guests) security (including cybersecurity, including improving the security of our network and information systems);

        g. general business operations and diligence (for example, to develop and maintain relationships with vendors, partners and other organizations and dealing with individuals who work for them); and

        h. providing our Services to you.

    d) Where the processing of your personal information is necessary for compliance with a legal obligation; for example, statutory tax retention periods, response to requests from government agencies (such as courts), customs authorities for customs clearance purposes.

If you would like to have more information about our legitimate interests to process your personal information, please contact us as set out below.

We will also receive information about you (including your personal information) if you use any other websites or apps operated or other services provided by us or our group companies. In this case, that information will be shared within the group and combined with information collected on this. We may also communicate with you through your social media accounts. 

We do not make automated decisions which has significant legal effects regarding you. However, if this changes in the future, we will ensure that such decision making is compliant with the applicable laws and that you are informed of such decision making in line with the applicable laws.

 

3. Ways we collect your data and sources of data

Your personal information is either (a) provided by you (e.g. via our Website / where you use our Services); (b) obtained from third parties (such as other entities in our group); or (c) obtained from publicly available sources (e.g. the Internet, Companies House).

We may collect your personal information if you or your company are supplying products and/or providing Services to us or if we are supplying products and/or providing Services to you or your company (including where we are carrying out direct marketing); and

In addition, we may also collect personal information about you from the following sources:

    • Directly and indirectly from activity on the Website. For example, from website usage details that are collected automatically. In addition, like many organisations, we use "cookies" which are small text files a website can use to recognize repeat users, facilitate the user's ongoing access to and use of the site and to track usage behaviour of, for example, the webpages you visit. Please see our Cookie Policy for further information;

    • From Social Media websites;

    • From strategic business partners that assist us in providing certain transactions and Services (e.g. authorised resellers, authorised business partners who may be collecting your parcels on behalf of us, credit card providers, payment processing, Social Media, product vendors, advertising networks, analytics providers, hosting and other strategic partners).

 

4. Legal and other requirements

As explained above, some of the personal information we request is required to provide the Services and if it is not provided, we may not be able to provide the relevant Services to you or provide information you have requested from us.

Your personal information may also be processed if it is necessary on reasonable request by a law enforcement or regulatory authority, body or agency, or in order to investigate, prevent or take action regarding suspected illegal activities or fraud, to enforce or apply our Terms of Use and other agreements, to protect the rights, property or safety of group companies, customers, clients and others or in the defence of legal claims. We will not delete personal information if relevant to an investigation or a dispute or until applicable law allows for it to be deleted. It will continue to be stored until those issues are fully resolved and it can be lawfully deleted.

Any personal information you supply to us through our Website must be complete and accurate. Please note that we can contact you to verify your personal information, if we need to.

 

5. How long we keep your information

We will keep your information for as long as it is reasonably necessary and to deal with claims. We will also retain your information as necessary to comply with legal, accounting or reporting requirements.  

There are also certain types of information, such as tax records, which require to be retained for a certain period by law.

In general terms, the criteria we use to determine the retention periods is as follows:

    • whether there are contractual or legal obligations that exist that require us to retain the data for a period of time;

    • whether you have interacted with us recently;

    • whether there is an ongoing legal claim that relates to any business (or otherwise) relationship you have with us, or that is otherwise related to your relationship with us; 

    • whether any applicable law, statute, or regulation allows for a specific retention period;

These criteria may also mean we adjust the period of time we retain the categories of personal information detailed above.

We will remove your personal information if we no longer need it for the purposes set out above.

Our retention practices in respect of certain personal information are as follows:

Account Information and Waybill Information:

    • Your Account Information and information on rights, interests and virtual assets in your account will no longer be accessible immediately after you cancel your account, however, accounts of some of the order placement channels have a pulling-back period (such as thirty days), so the information may be deleted after such period. The information cannot be recovered once it is deleted.

    • In order to satisfy your inquiry, your Waybill Information will be reserved in SF’s live system for thirty days to six months (depending on the specific order placement channel) and you may inquire about shipment routing information on the official website of SF Express through the shipper indicated on the waybill, the receiver’s mobile phone number or the waybill number and the order placement channel (such as SF Express app); after expiry of such period, we will remove your Waybill Information from SF’s foreground system, so that such information cannot be retrieved or accessed.

    • Note that we will need our Account Information and Waybill Information to perform the customs clearance process. Customs laws dictate that we have to retain/store - certain of - those personal information. Generally, this period varies from 3 to 7 years, depending on the applicable country and customs laws. In those cases, we will only store the personal information necessary to meet our legal obligations.

Marketing:

    • We will retain a copy of your contact details if you object or opt-out of receiving direct marketing communications from us. We will add your details to our suppression list to ensure you do not receive any future marketing communications from us. Also, we will not delete personal information if relevant to an investigation or a dispute. It will continue to be stored until those issues are fully resolved.

Disputes:

    • Where relevant, we will also retain your personal information for the length of any applicable limitation period for claims which might be brought against us later (e.g. generally between six to ten years depending on the applicable jurisdiction). This will enable us to exercise any legal rights we may have or to defend any legal claims that may arise. In certain circumstances, personal information may need to be retained for a longer period of time, for example, where we are in ongoing correspondence with you or there is a continuing legal claim or regulatory investigation. The period we retain your personal information for will depend on the duration of such claim or investigation and any need for us to ensure we retain necessary data in order to exercise any legal rights we may have.

Please contact us at joeyxie@sf-express.com for more information on the specific retention periods that apply to your personal information.

 

6. Information we share

There are certain circumstances where we transfer your personal information to third parties such as our service providers, group companies and law enforcement agencies. These are as follows:

    • We share information about you with other members of our group of companies so we can provide the best service across our group. They are required to keep and use your information in accordance with this Notice.

    • We will share your personal information with and access information from analytics and search engine providers that assist us in the improvement and optimisation of the website and the app and for better personalisation of content and advertising.

    • We share your information with our authorised business partners, resellers, certain contractors or service providers such as data processors. They may process your personal information for us, for example, if we use a cloud service provider (such as AWS). Other service providers include advertising agencies, IT suppliers, backup and disaster recovery specialists, email providers and outsourced call centres. Our suppliers and service providers will be required to meet our standards on processing information and security. The information we provide them, including your information, will only be provided in connection with the performance of their function. They will not be permitted to use your information for any purposes other than those outlined in this Notice.

    • We may share your information with payment processors. When you place an order, you may choose the payment services provided by SF’s related party or any third party payment organization cooperating with SF (e.g. SF Financial, Alipay, WeChat Pay, Unionpay, NetsUnion, hereinafter referred to as “Payment Institutions”), and we will provide your SF order number and transaction amount information to these Payment Institutions to confirm your payment instruction and complete payment.

Your personal information may be transferred to other third party organisations in certain scenarios:

    • if we discuss selling or transferring part or all of our business – the information may be transferred to prospective purchasers under suitable terms as to confidentiality;

    • if we are reorganised or sold, information may be transferred to a buyer who can continue to provide services to you;

    • if we're required to by law, or under any regulatory code or practice we follow, or if we are asked by any public or regulatory authority – for example the Police or customs authorities;

    • if we are defending a legal claim your information may be transferred as required in connection with defending such claim.

Your personal information may be shared if it is made anonymous and aggregated, as in such circumstances the information will cease to be personal information.

 

7. Where your information will be held

The information that we collect from you may be transferred to and stored at a destination outside the European Economic Area (EEA), including China which does not have equivalent data protection laws to those applicable to Europe. It may also be processed by staff operating outside the UK and/or EU who work for us, for one of our affiliated companies, or for the organisation that hosts our Website.

When we transfer your personal information outside the United Kingdom and/or European Economic Area (the EEA), we will take relevant measures to protect the information in accordance with applicable laws and regulations. However, regardless of the differences of destination countries of information transfer, we will protect such information at a level not lower than the data protection level of the country in which the personal information was originally collected.

For transfers outside the United Kingdom and/or EEA, we will typically use the Standard Contractual Clauses (SCCs) as a way to ensure adequate safeguards are in place. The European Commission has approved these model contracts. If you would like to obtain copies of the regulator-approved SSCs please contact us on the contact details below.

 

8. Your Rights

You have certain rights in relation to your information. Some of these rights will only apply in certain circumstances. If you would like to exercise, or discuss, any of these rights, please contact us  at joeyxie@sf-express.com.

    • Access: you are entitled to ask us if we are processing your information and, if we are, you can request access to your personal information.  This enables you to receive a copy of the personal information we hold about you and certain other information about it.

    • Correction: you are entitled to request that any incomplete or inaccurate personal information we hold about you is corrected.

    • Erasure: you are entitled to ask us to delete or remove personal information in certain circumstances. There are also certain exceptions where we may refuse a request for erasure, for example, where the personal information is required for compliance with law or in connection with claims.   

    • Restriction: you are entitled to ask us to suspend the processing of certain of your personal information about you, for example if you want us to establish its accuracy or the reason for processing it.

    • Transfer: you may request the transfer of certain of your personal information to another party.

    • Objection: where we are processing your personal information based on a legitimate interest (or those of a third party) you may challenge this.  However, we may be entitled to continue processing your information based on our legitimate interests or where this is relevant to legal claims.  You also have the right to object where we are processing your personal information for direct marketing purposes.

    • Consent: where we are processing personal information with consent, you can withdraw your consent.

You also have a right to lodge a complaint with a supervisory authority, in particular in the Member State in the European Union where you are habitually resident where we are based or where an alleged infringement of Data Protection law has taken place. In the UK you can make a complaint to the Information Commissioner's Office (Tel: 0303 123 1113 or at www.ico.org.uk).

 

9. Security

We are committed to keeping your personal information safe. We've got physical, technical and administrative measures in place to prevent unauthorised access or use of your information.

 

10. Links to third party website

Our Website, newsletters, email updates and other communications may, from time to time, contain links to and from the websites of others including our partner networks, advertisers and other group companies and/or social networks as offered to you and supported by your browser.

The personal information that you provide through these websites is not subject to this Notice and the treatment of your personal information by such websites is not our responsibility. If you follow a link to any of these websites, please note that these websites have their own Notices which will set out how your information is collected and processed when visiting those sites. For more information about the purpose and scope of data collection and processing in connection with social sharing features, please visit the Notices of entities through which you choose to share.

 

11. Changes to this Notice

This notice may be changed from time to time.

If we change anything important about this notice (the information we collect, how we use it or why) we will highlight those changes at the top of the notice and provide a prominent link to it for a reasonable length of time following the change.

Once this notice is posted on our Website, it will automatically come into force. The latest version of this notice will prevail over all previous versions.

If you would like to access previous versions of this notice please contact us.

 

12. How to contact us

If you would like more information about the way we manage personal information that we hold about you, or are concerned that we may have breached your privacy and wish to make a complaint, please contact us as set out below. We will do our best to resolve your complaint.

If you have any questions about this notice please contact us:

Email address: joeyxie@sf-express.com,

Address:4th Floor Imperial House, 8 Kean Street, London, United Kingdom, WC2B 4AS.

 

Annex 1

Contact Details of Data Controllers subject to this Notice

 

SF Express (Europe) Co., Ltd.:

Address: 4th Floor Imperial House, 8 Kean Street, London, United Kingdom, WC2B 4AS

If you have questions, please contact usat:

E-mail: joeyxie@sf-express.com 

 

S.F. Express Co., Ltd.:

Address: Shenzhen Software Industry Base, Xuefu Road, Hi-tech Industrial Park South, Shenzhen, 518054, P.R. China

If you have any questions for S.F. Express Co., Ltd., please contact us by using the contact details provided above.

 

SF Technology Co. Ltd.:

Address: Shenzhen Software Industry Base, Xuefu Road, Hi-tech Industrial Park South, Shenzhen, 518054, P.R. China

Name and contact details of the representative of SF Technology Co. Ltd. is as follows:

Name: SF Express (Europe) Co., Ltd.

Contact details: joeyxie@sf-express.com 

If you have any questions for SF Technology Co. Ltd., please contact the Representative by using the contact details provided above.

 

Annex 2

Responsibilities in relation to Joint Controllership

 

SF Express (Europe) Co., Ltd. ("SF UK") and S.F. Express Co., Ltd. ("SF China") are joint data controllers in respect of the processing activities that they carry out when providing our services to you. This means that they may jointly determine the purposes and means of processing your personal data.

 

The table below sets out the arrangements that have been agreed between SF China and SF UK as joint data controllers, including who will be responsible for providing you with information about how and why we use your information and who will be responsible for dealing with a request from you.

 

Responsibilities 

Responsible 

Provide privacy notices

Both

Responding to data subjects (including data subject individual rights requests)

SFUK

Inform Data Subject of Personal Data Breach

SFUK

Contact point for all personal data enquires

See Annex 1