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PRIVACY POLICY

PRIVACY POLICY OF SOTRADEX LIMITED

Document updated on June 5, 2025

SOTRADEX LIMITED ("Sotradex," "our," "we," and "us") and our partners respect your privacy.

We ask that you carefully read this privacy policy to understand how your personal data is collected, processed, and stored when you use this website, www.sotradex.com.

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The term “personal data” refers to any information relating to a natural person that allows them to be identified, directly or indirectly, from a single piece of data or from the cross-referencing of a set of data.

All personal data collected on this website is processed under the responsibility of SOTRADEX LIMITED, a private company limited by shares registered in Hong Kong, with a share capital of [To be completed], registered under CR No. 0841700 and Business Registration No. 33490701, with its registered office at RM 1815 KWONG SANG HONG CTR, NO 151-153 HOI BUN ROAD KWUN TONG, HONG KONG. The processing of this data is carried out in compliance with applicable data protection regulations, including Regulation (EU) 2016/679 of April 27, 2016 (GDPR) for data subjects located in the European Union, as well as the laws of Hong Kong.

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Within the meaning of the applicable data protection regulations, SOTRADEX LIMITED is therefore the data controller.

 

This privacy policy describes:

  1. How Sotradex uses your personal data

  2. How Sotradex shares your personal data

  3. How Sotradex protects your personal data

  4. Where Sotradex hosts and transfers your personal data

  5. How you can exercise your rights regarding your personal data

  6. Updates to the privacy policy

  7. How to contact us

I. How Sotradex uses your personal data

Sotradex may use your personal data for the following purposes, primarily within the scope of its B2B activity of designing, developing, and manufacturing textile products for large distribution companies and resellers:

  • Responding to your contact request made through our website and managing our communications.

  • Creating and managing a file of B2B prospects and clients for commercial relationship management.

  • Compiling website traffic statistics and analyzing site usage for optimization.

  • Complying with our legal and regulatory obligations.

  • Providing information about our services, know-how, and expertise, as described in our strategic document.

The collection of your personal data to respond to your information requests is based on Sotradex's legitimate interest in better addressing your inquiries and establishing B2B commercial relationships. When we use your data for other specific purposes requiring your consent (e.g., sending a newsletter if this feature is implemented), we will explicitly request it.

II. How Sotradex shares your personal data

Within Sotradex, and for each processing purpose, your personal data is collected, processed, and stored by authorized personnel, solely within their respective competencies, including teams based in Hong Kong responsible for business development, customer support, or administration.

We do not share personal data with other companies, organizations, or individuals unless one of the following circumstances applies:

(1) Sharing with prior consent: After obtaining your consent, Sotradex will share the information you have authorized with the specific third parties or categories of third parties indicated at the time of collecting your consent.

(2) Sharing with our service providers: Sotradex may also disclose your information to companies that provide services for us or on our behalf. Examples of these service providers include companies that offer IT services, such as our host (Wix Studio) or our email service provider, or that carry out marketing activities on our behalf. These service providers may use your information only for the purpose of providing services on behalf of Sotradex.

(3) In performance of a legal obligation, sharing in accordance with laws and regulations: Sotradex may share your information as stipulated by laws and regulations to resolve legal disputes, or as required by judicial or administrative authorities under the law, including those of Hong Kong and the European Union where GDPR applies.Sotradex will ensure the legality of any sharing of personal data through data processing agreements with the companies with which your personal data is shared, obliging them to comply with this privacy policy and to take appropriate security and confidentiality measures when processing personal data, especially when these providers process data of residents of the European Union in accordance with GDPR requirements.

III. How Sotradex protects your personal data

Sotradex attaches great importance to the security of your personal data and has adopted industry-standard practices to protect your personal data and prevent unauthorized access, disclosure, use, modification, damage, or loss of this information.

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We have also taken the necessary precautions to ensure, through our host (Wix Studio), the security and confidentiality of the data and, in particular, to prevent it from being distorted, damaged, or communicated to unauthorized persons.

Sotradex also adopts the following organizational measures:

(1) We take reasonable and feasible measures to ensure that the personal data collected is minimal and relevant to what is necessary for the purposes for which it is processed.

(2) We retain your personal data for the period strictly necessary for the purpose of the processing, unless the retention of your data is required or permitted by applicable law, including the laws of Hong Kong and the obligations arising from the GDPR for the data of EU residents. For example, data that may be used for the establishment, exercise, or defense of legal claims may be retained in accordance with applicable statutes of limitations.

(3) We deploy access control mechanisms to ensure that only authorized personnel can access your personal data.

In the event of a personal data breach, Sotradex will comply with the applicable legal and regulatory requirements for notifying data breaches to the competent supervisory authorities (including those in the EU, where applicable) and/or the data subjects concerned.

IV. Where Sotradex hosts and transfers your personal data

Given that Sotradex operates from Hong Kong, the initial collection and processing of your personal data may involve a data transfer to Hong Kong.

 

Your personal data related to the use of the website is hosted on the hosting infrastructures of our host, Wix Studio. The registered office of Wix is located at 40 PORT DE TEL AVIV TEL AVIV JAFFA 6350671.

Some third parties to whom we communicate your personal data may also be located in countries outside the European Union or the European Economic Area (EEA). This may include:

  • Our teams and operations at the Sotradex headquarters in Hong Kong.

  • Our partner factories and sourcing and production providers located in China and Bangladesh, to the extent necessary for the development, manufacturing, or shipping of B2B products.

  • Other service providers (e.g., IT services, communication) potentially located outside the EU/EEA.

 

When such transfers exist and concern the personal data of residents of the European Union, we ensure that these transfers of personal data are framed in accordance with applicable regulations (notably the GDPR) to ensure an adequate level of data protection. This may be based on an adequacy decision by the European Commission for certain countries, or through appropriate legal instruments such as data transfer agreements incorporating the Standard

 

Contractual Clauses of the European Commission.

For any request concerning the recipients and data transfers we carry out outside the European Union, please contact us at the addresses indicated in the "How to contact us" section below.

V. How you can manage your rights regarding your personal datA

In accordance with the provisions of the GDPR and the amended French Data Protection Act (when applicable), you have the right to access, rectify, erase, restrict the processing of, and object to the processing of your personal data, as well as the right to define directives concerning the fate of your data after your death and the right to data portability.

 

You also have the right to lodge a complaint with the Commission Nationale Informatique et Libertés (CNIL) for France and with a competent supervisory authority for any other EU member state according to your usual place of residence, your place of work, or the place where the violation of your rights allegedly occurred if you believe that the processing of your data does not comply with the applicable texts. This remedy may be exercised without prejudice to any other remedy before an administrative or judicial court, which is also a right you have.

 

You can contact us at any time at the addresses indicated in the "How to contact us" section below to exercise your rights regarding personal data under the conditions set by the applicable regulations. You must indicate which right you intend to exercise as well as all the necessary details so that we can respond to your request.

These rights are exercised under the conditions set by the applicable regulations.

The right of access means that you can ask us at any time to indicate whether we are processing personal data about you and, if so, to indicate which personal data is concerned as well as the characteristics of the processing carried out.

The right to rectification means that you can ask us to rectify your personal data when it is inaccurate. You can also ask for your personal data, if incomplete, to be completed to the extent that it is relevant to the purpose of the processing in question.

The right to erasure means that you can request the deletion of your personal data, especially when:

Its retention is no longer necessary for the purposes for which it was collected;

Your personal data is processed on the basis of your consent, you wish to withdraw this consent, and there is no other legal basis to justify the processing;

You have objected to the processing of your personal data and therefore wish for it to be erased;

Your personal data has been unlawfully processed;

Your personal data must be erased to comply with a legal obligation.

The right to restriction of processing means that you can ask us to limit the processing of your personal data:

When you contest the accuracy of your personal data for a period allowing us to verify its accuracy;

When, following processing established as non-compliant, you prefer the restriction of processing to the complete erasure of your personal data;

When we no longer need your personal data for the purposes of processing but it is still necessary for you for the establishment, exercise, or defense of legal claims;

When you have objected to the processing of your personal data and wish for a restriction of processing for the period allowing us to verify whether the legitimate reason you invoke is justified. The restriction of processing means that the processing of your personal data will then be limited to the storage of your corresponding personal data. We will then not carry out any other operation on the personal data in question.

The right to object means that you can object to the processing of your personal data, especially when this processing is based on the pursuit of Sotradex's legitimate interest. The right to object is exercised subject to justifying a legitimate reason related to your particular situation. We will then cease the processing in question unless there are legitimate and compelling reasons to justify its continuation in accordance with applicable regulations.

The right to define directives concerning the fate of your data after your death allows you to make known your instructions concerning the retention, erasure, and communication of your personal data after your death.

The right to data portability means that you can ask us, under the conditions set by the applicable regulations, to receive your personal data in a structured, commonly used, and machine-readable format, and to transmit it to you, or to ask us to transmit it directly to a third party of your choice when this is legally and technically possible.

 

When we process your personal data on the basis of your consent, you finally have the right to withdraw your consent at any time by contacting us at the addresses indicated in the "How to contact us" section or by clicking on the unsubscribe link present in each of our communications (if this option is available).

However, the withdrawal of your consent does not affect the validity of the processing carried out before this withdrawal.​

VI. Updates to this privacy policy

Sotradex reserves the right to modify or update, in whole or in part, this privacy policy at any time, due to changes in the applicable data protection regulations or the data processing carried out.

Any substantial modification of the privacy policy will be notified to you by email when you have provided us with a valid email address and will be published on the website. We recommend that you regularly review this Policy to have a perfect understanding of our commitments regarding the security and protection of your personal data.

VII. How to contact us

If you have questions, comments, or suggestions, please contact us:

By email at contact@sotradex.com.hk.

By post at RM 1815 KWONG SANG HONG CTR, NO 151-153 HOI BUN ROAD KWUN TONG, HONG KONG.

If you are not satisfied with the response provided by Sotradex to a request to exercise rights in accordance with Article V above or if you wish to report a breach of the applicable data protection regulations, you have the right to lodge a complaint with the data protection authority of your country of habitual residence or work in the EU, such as the CNIL for France (CNIL - 3 Place de Fontenoy - TSA 80715 - 75334 PARIS CEDEX 07 or on its website www.cnil.fr).

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