Privacy Policy & Cross-Border Transfer Authorization

GTE Privacy Policy

Release Date: August 1, 2026　　Last Updated Date: August 1, 2026　　Version Effective Date: August 1, 2024

GTE (hereinafter referred to as “we”) attaches great importance to the privacy and personal information security protection of users. We will take corresponding security protection measures in accordance with the requirements of laws and regulations and try our best to protect the security and control of your personal information.

We would like to explain to you, through the Privacy Policy (hereinafter referred to as the “the Policy”), how the Site collects, uses, stores and shares your personal information and how you can exercise your user rights. This policy applies to your personal information involved in the process of your visiting, browsing, using our site, applying for or using our services, participating in our research related to you, and communicating with us in any way. We will collect, use, store, disclose and protect your personal information in accordance with this Policy.

Please carefully read and fully understand all the contents of this Privacy Policy before visiting, browsing and using this Site. Please contact us if you have any questions, comments or suggestions on the contents of this Policy during the reading process.

We understand the importance of personal information to you and will do our best to keep your personal information secure. We are committed to maintaining your trust in us, adhering to the following principles to protect your personal information security: the principle of consistent rights and responsibilities, the principle of clear purpose, the principle of choosing consent, the principle of minimum necessity, the principle of ensuring information security, the principle of subject participation, the principle of openness and transparency, etc. At the same time, GTE promises that we will take appropriate security measures to protect your personal information in accordance with established security standards in the industry.

Please read and understand the Privacy Policy carefully before using our services.

1. How We Collect and Use Your Personal Information

Personal information refers to all kinds of information recorded electronically or in other ways that can identify a specific natural person or reflect the activities of a specific natural person alone or in combination with other information.

In the course of your use of GTE site, we will collect personal information provided by you at the time of use or generated as a result of its use in the following ways for the purpose of providing services to you and optimizing our services:

The types of your personal information we collect and use include two types: the first: personal information necessary for the essential business functions of our products/services: such personal information is necessary for the normal operation of the products/services and you need to authorize us to collect it. If you refuse to provide it, you will not be able to use our products/services properly; the Second: personal information that may be collected for extended business functions: this personal information is required for non-essential business functions, and you can choose whether to authorize us to collect it. If you refuse to provide it, the extended business function will not be realized or the effect we intend to achieve will not be done, but your normal use of the essential business function will not be affected.

When you participate in the message activities of GTE site, you need to provide personal information such as name, email address, company name, title, etc. Such information is not personal sensitive information, but we will strictly protect your personal information. You can choose whether to participate in the message activities according to your own needs.

2. How We Use Cookies and Similar Technologies

We may use Cookies on our site. Some of them are necessary, while others are not, but help us to enhance site navigation, analyze site usage, and assist in our marketing efforts. You can accept the use of non-necessary Cookies by clicking on the “OK” button or reject it by clicking on the “Reject” button. You can also only agree to certain cookie groups (preferences, statistics, marketing) by selecting them and clicking “Allow selection”. You can access the cookie settings at any time and also deselect Cookies later on at any time. For more information, please see our Privacy Policy, which can be found in the footer of our site, as well as our Legal Notice.

Cookies are small text files that site can use to improve the efficiency of the user experience.

By law, we may store Cookies on your device if they are absolutely necessary for the operation of the Site. For all other types of cookies, we need your permission.

This Site uses different types of Cookies. Some Cookies are placed by a third-party service that appears on our page.

You may change or withdraw your consent to the Cookie statement on our site at any time.

We will not share your personal information with any third party other than us without your consent except in the following cases:

To provide our services to you. We may share your information with affiliates and other third parties to achieve the core functions you need or provide the services you need;
To maintain and improve our services. We may share your information with affiliates and other third parties to help us provide you with more targeted and complete services;
To achieve the purposes set forth in Section I, “Collect and Use Personal Information” of this Privacy Policy;
Provided on the basis of social and public interests in accordance with laws and regulations.
We will share your personal information only for legal, legitimate, necessary, specific and definite purposes. Companies, organizations, and individuals with whom we share personal information are subject to strict confidentiality agreements to process the information in accordance with our instructions, this Privacy Policy, and any other relevant confidentiality and security measures.

(II) Transfer

As our business continues to grow, we may merge, transfer assets or similar transfers, and your information may be transferred as part of such.

(III) Disclosure

We will only disclose your personal information under the following circumstances and only if we take security measures that meet industry standards:

Disclose the information designated by you according to your requirements and in the manner you expressly agree to disclose;
In the event that your information must be provided in accordance with laws and regulations, mandatory administrative enforcement or judicial requirements, we may disclose your information according to the type of information required and the manner of disclosure. Subject to laws and regulations, when we receive the above-mentioned request for disclosure of information, we will require the receiving party to produce the corresponding legal documents, such as summon or letter of inquiry. We firmly believe that the information we are asked to provide should be as transparent as possible to the extent permitted by law. All requests are carefully reviewed to ensure that they have a legitimate basis and are limited to data that law enforcement department has a legitimate right to obtain for specific investigative purposes.

Your prior authorization and consent are not required to share, transfer, or disclose your information in the following cases:

It is related to national security and national defense security;
It is related to public safety, public health and significant public interests;
It is related to judicial or administrative law enforcement such as criminal investigation, prosecution, trial and execution of judgment;
It is difficult to obtain your consent for the purpose of safeguarding your or other individual’s life, property and other significant legitimate rights and interests;
Information that you disclose to the public on your own;
Information collected from legally publicly disclosed information, such as legitimate news reports, government information disclosure and other channels.

The sharing, transfer and disclosure of de-identified personal information in accordance with the laws and regulations and the data receiving party’s inability to recover and re-identify the subject of the information shall not be deemed as the external sharing, transfer and public disclosure of personal information, and the storage and processing of such data will not require further notice to you or your consent.

4. How We Protect and Store Your Personal Information

(I) How We Protect and Store Your Personal Information

In accordance with legal requirements, GTE has taken extensive technical and organizational measures to ensure that the level of protection meets or in some cases exceeds the requirements of the Personal Information Protection Law of the People’s Republic of China. The measures taken protect not only personal data but also other data processed on the same system.
Your data security is very important to us, so all areas of our site where you can actively enter data use encrypted data transfers such as TLS (Transport Layer Security) to protect your data from the unauthorized third-party access.
If you register to use the access-protected area of the GTE site, you should keep the login details you receive in a safe place and prevent the third party’s access. If the computer you are logged in is used by more than one person, do not forget to log off correctly at the end of each session and close the browser window you are using.
With a wide range of technical and organizational security precautions, GTE can protect your personal data from accidental or intentional manipulation, loss, destruction or access by unauthorized third parties. As technology develops, we are continually improving these precautions.

Please understand that, due to the limitation of technology and risk prevention, even though we have tried our best to strengthen the security measures, we cannot always guarantee the 100% security of information, and problems may occur due to situations beyond our control.

(II) Duration of information storage

We promise that the storage time of your personal information is always within the reasonable and necessary period. We will store the user information according to the business needs. If the user information exceeds the storage period, GTE will delete your personal information or anonymize your personal information within a reasonable period of time.

5. Your Rights

(I) You have the right to require us to guarantee the security of your personal information in accordance with the laws, regulations and provisions of this Policy, and to exercise the rights related to your personal information granted by applicable laws and regulations.

(II) You have the right to inquire us whether we hold your personal information and to check and copy your personal information.

(III) You have the right to change the scope of your authorized consent or to withdraw your authorization. When you change the scope of your authorization, we will no longer process the corresponding personal information. However, your decision to withdraw your consent will not affect our previous processing of personal information based on your authorization.

(IV) You have the right to require us to delete or otherwise properly process your personal information beyond the retention period in accordance with laws and regulations, this Policy and the agreement between you or the relevant customers and us. If we cease operating, we will promptly stop collecting your personal information in a timely manner, notify you of the notice of stopping the operation in the form of an announcement, and delete or anonymize your personal information that we hold, unless otherwise specified by laws and regulations or regulatory authorities, it is technically difficult to delete personal information.

(V) This Policy will not limit your other rights as the subject of personal information according to applicable laws and regulations.

6. How We Handle the Personal Information of Minors

(I) We attach great importance to the protection of the personal information of minors. If you are a minor, you should obtain your parents’ or legal guardian’s written consent in advance before using our services. We will protect the personal information of minors in accordance with relevant national laws and regulations.

(II) For the personal information of the minor that has been collected with the consent of the parents or legal guardians of the minor, we will only use or publicly disclose the relevant information permitted by law, with the explicit consent of the parents or legal guardians when necessary to protect the minors.

(III) If we find that personal information of a minor has been collected without the prior consent of the minor’s parents or legal guardians, we will delete the relevant data as soon as possible.

7. How to Transfer Your Personal Information Globally

In principle, the personal information we collect and generate in the People’s Republic of China will be stored domestically. Because we provide products or services through resources and servers around the world, this means that your personal information may be transferred to or accessed from foreign jurisdictions where regulation permits and the law applies. If we transfer your personal information abroad, we will comply with applicable laws and regulations for cross-border data transfer. Whether personal information is processed within or outside the country, your personal information will be protected by confidentiality and security rules to which GTE members and its employees, as well as the third parties, are under applicable personal information or data protection laws. For details please refer to the Authorization Letter for Cross-border Transfer of Personal Information.

8. How to Update this Policy

Our Privacy Policy may change. We will not reduce your personal privacy rights without your consent. We will notify you by prompting a notice on our home page or sending you an email before the revisions takes effect. In this case, by continuing to use our services, you agree to be bound by the revised Privacy Policy.

9. How to Contact Us

We welcome your feedback. If you have any comments, complaints or questions about this Privacy Statement or our handling of your personal data, or would like to exercise any of your rights, you can contact us in the following ways:

Email: info@gteconnect.com

10. Settlement of Disputes

(I) The interpretation and dispute resolution of this Privacy Policy shall be governed by the laws of the People’s Republic of China (excluding Hong Kong, Macao and Taiwan). You agree to submit any dispute arising from this Privacy Policy and our handling of your personal information to Shanghai Arbitration Commission for arbitration; The arbitration shall be final and legally binding on both parties.

(II) If you think that our handling of personal information has damaged your legitimate rights and interests, you may also choose to report to relevant government departments.

(III) The title of this Privacy Policy is for convenience of reading only and does not affect the meaning or interpretation of any provision in the text.

Authorization Letter for Cross-border Transfer of Personal Information

[Notice] For your legitimate rights and interests, please ensure you are a natural person with full capacity for civil rights, carefully read and fully understand all the terms of this Authorization Letter (especially those bold and underlined terms) prior to signing this Authorization letter. If you have any concerns and objections, please do not continue and immediately contact us (Email: info@gteconnect.com) for any explanation and clarification on relevant contents. Your confirmation, box selection or acceptance in other ways indicates that you have read and agreed to this authorization letter, which would immediately take effect in law and be legally binding between you and GTE.

To: GTE

I hereby agree and authorize, during the relevant business application and the business conduct process, as follows:

I. Processing Purposes, Methods and Types of Personal Information

I am aware that GTE, as a consulting firm operating in mainland China, for different processing purposes, may transfer my personal information to servers located in jurisdictions outside mainland China (e.g. Hong Kong, China) for processing, or provide it to recipients outside mainland China, or entrust relevant overseas service agencies to process it.

I hereby authorize GTE to provide my personal information to its affiliates outside of GTE for the purpose of providing services to me and for the fulfillment of my needs in connection with the related activities.

II. Name and Contact Information of Overseas Recipient

GTE Technologies Hong Kong Limited; Email: info@gteconnect.com

III. Personal Data Protection Method

I am fully aware that:

Unless otherwise specified in laws and administrative regulations, GTE’s retention period for personal information shall be the shortest period of time necessary to achieve the purpose. After the expiration of the corresponding retention period, GTE will destroy, delete or anonymize the relevant information, or stop processing other than storage and taking necessary security measures if destruction, deletion, or anonymization are not possible.

GTE will conduct corresponding export security assessment of personal information in accordance with requirements of laws and regulations, take all necessary and appropriate safeguards to ensure the security of my personal information during transmission, enter into appropriate data processing agreements with the overseas recipients, adopt standard data protection contracts when necessary, and require the overseas recipients of my personal information to provide adequate protection and security.

IV. My Rights, Methods and Procedures for the Exercise of Such Rights

I am aware and understand that I am entitled to access, copy, correct, supplement and delete my personal information, change and withdraw my authorization for the use of my personal information by GTE and the data recipient, and I will exercise such rights in accordance with the methods and procedures set forth in GTE’s Privacy Policy, including any doubts I may have about the data recipient and its handling of information, either by contacting GTE via the following contact information or by contacting the data recipient directly through the contact information listed in this Authorization Letter.