1. Introduction
China Trade Recovery ("we," "our," or "us"), operated by Attorney Roy, a PRC-licensed attorney, is committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you visit our website getmymoneyback.cn, use our case evaluation form, or engage our legal services.
This policy complies with applicable data protection laws including the EU General Data Protection Regulation (GDPR), the California Consumer Privacy Act (CCPA), and the Personal Information Protection Law of the People's Republic of China (PIPL).
2. Information We Collect
2.1 Information You Provide Voluntarily
When you submit a case evaluation request, contact us via email, or engage our services, we may collect:
- Identity data: Full name, company name, job title
- Contact data: Email address, phone number, country of residence
- Case data: Contract documents, payment records, correspondence with Chinese suppliers, evidence of fraud or breach
- Communication data: Messages, inquiries, and any information you choose to share
2.2 Information Collected Automatically
When you visit our website, we automatically collect:
- Technical data: IP address, browser type, operating system, device information
- Usage data: Pages viewed, time spent, referral source, click patterns
- Cookie data: See Section 7 for our Cookie Policy
We use Google Analytics 4 (GA4) for website analytics. GA4 anonymizes IP addresses by default. You can opt out of Google Analytics tracking via the Google Analytics Opt-out Browser Add-on.
3. How We Use Your Information
We use your personal data exclusively for the following purposes:
- Legal services: To evaluate your case, provide legal advice, and represent you in Chinese legal proceedings
- Communications: To respond to inquiries, send case updates, and deliver retainer agreements
- Website improvement: To analyze usage patterns and improve our website experience
- Legal compliance: To comply with applicable laws, court orders, and regulatory requirements
- Attorney-client privilege: All case-related communications are protected by attorney-client confidentiality under PRC law
We do NOT: sell your personal data, use it for automated decision-making, or share it with third parties for marketing purposes.
4. Legal Basis for Processing (GDPR)
For visitors from the European Economic Area (EEA), we process personal data on the following legal bases:
- Contractual necessity: Processing necessary to evaluate and potentially enter into a legal services agreement
- Legitimate interests: Website analytics and security monitoring
- Consent: Where you have explicitly provided consent (e.g., submitting a case evaluation form)
- Legal obligation: Compliance with PRC attorney professional conduct rules and applicable laws
5. Data Sharing and Disclosure
We may share your data only in these limited circumstances:
- With Chinese courts and tribunals: As necessary for litigation, arbitration, or enforcement proceedings
- With service providers: Cloud hosting (located within China, GDPR-compliant), email services, and analytics (Google Analytics)
- Legal requirements: If required by law, court order, or governmental authority
- With your consent: Any other sharing only with your explicit consent
6. Data Retention
We retain personal data only as long as necessary:
- Case evaluation inquiries (no retainer): 12 months from last communication
- Active client files: Duration of representation + 10 years (PRC attorney professional requirement)
- Website analytics data: 26 months (Google Analytics default)
7. Cookies
Our website uses minimal cookies:
- Essential cookies: Session management (strictly necessary, no consent required)
- Analytics cookies: Google Analytics (_ga, _gid) — anonymized, used for aggregate traffic analysis
You can manage cookie preferences through your browser settings. Blocking essential cookies may affect website functionality.
8. Your Rights
GDPR Rights (EEA Residents)
- Right to access your personal data
- Right to rectification of inaccurate data
- Right to erasure ("right to be forgotten")
- Right to restrict processing
- Right to data portability
- Right to object to processing
- Right to withdraw consent
CCPA Rights (California Residents)
- Right to know what personal information is collected
- Right to delete personal information
- Right to opt-out of sale (we do not sell data)
- Right to non-discrimination for exercising CCPA rights
PIPL Rights (PRC Residents & Data Processed in China)
- Right to know and decide on personal information processing
- Right to access and copy personal information
- Right to correction and deletion
- Right to withdraw consent
To exercise any of these rights, contact us at the email address below. We respond within 30 days.
9. International Data Transfers
Your data may be transferred to and processed in China, where our legal practice operates. China maintains data protection standards under PIPL that are recognized as providing adequate protection. For EEA residents, we implement Standard Contractual Clauses (SCCs) where applicable.
10. Data Security
We implement appropriate technical and organizational measures to protect your personal data, including:
- SSL/TLS encryption for all data in transit
- Encrypted storage for case files and evidence
- Access controls limited to authorized legal personnel
- Regular security assessments
11. Children's Privacy
Our services are not directed to individuals under 18. We do not knowingly collect personal data from children.
12. Changes to This Policy
We may update this Privacy Policy periodically. Material changes will be notified via our website. Continued use after changes constitutes acceptance.
13. Contact Us
For privacy-related inquiries or to exercise your data rights:
- Email: privacy@getmymoneyback.cn
- Mail: Attorney Roy, China Trade Recovery, Chengdu, Sichuan, PRC
- Response time: Within 30 days (GDPR/CCPA) or 15 days (PIPL)
If you are an EEA resident and believe we have not adequately addressed your concerns, you have the right to lodge a complaint with your local supervisory authority.