Privacy Policy

This Privacy Policy applies to the services provided by the KONJA group (hereinafter “KONJA”, “we”, “us”) through its official website. KONJA respects and protects your personal privacy. This policy is prepared in accordance with the General Data Protection Regulation (Regulation (EU) 2016/679, “GDPR”) and other applicable laws. It aims to explain, in a fair, lawful and necessary manner, when and what personal data we collect, for what purposes, how we protect it, what rights you enjoy, and how to contact us.

Please read this policy carefully before using the website or submitting any information to us. By accessing the website, submitting a form, or otherwise interacting with us, you confirm that you have read, understood and agreed to all terms of this policy.

1. Rights Statement

Unless otherwise specified, all rights (including but not limited to intellectual property rights and trade secrets) in the products, technologies, data, programs, layout designs, patterns, processes, audio, video and other information on this website belong to KONJA. Such rights are protected by the Civil Code of the People’s Republic of China, the Copyright Law of the People’s Republic of China, the Anti-Unfair Competition Law of the People’s Republic of China and other applicable laws, regulations, normative legal documents and relevant international treaties. Any violation of the above rights may lead to civil, administrative or criminal liability.

The rights of third parties involved in this website remain with their respective owners. Without the prior written consent of KONJA, no one may use the above information without authorization, otherwise we will pursue legal liability. If you have any needs, please obtain our written permission through the contact channels at the end of this policy.

When accessing this website, if you need to use software or drivers provided by the website, you must comply with the accompanying license agreement. When visiting this website, please also comply with applicable laws and regulations.

2. Data Controller and Contact

KONJA Headquarters, as a group affiliate, may act as a Processor under a written instruction from the Data Controller to assist with the processing under this policy. All material decisions regarding processing are made by the EU Data Controller. As the controller is established in the EU, no separate EU representative under Article 27 GDPR is required.

If a separate recruitment section of the website collects your CV/resume information, that processing will be carried out by the relevant recruiting entity as an independent Data Controller, and is subject to the additional notice on that page.

3. What Personal Data We Collect

We only collect the personal data that is necessary when you actively use the website functions, following the principle of data minimisation. The specific categories include:

• Information you fill in and submit through the “Contact Us” form: name, company, email, phone, country/region and the message body.
• Log information automatically collected when you visit the website, for operational security and reliability: IP address, access time, browser type and version, operating system, referring page, and time spent.
• Information you voluntarily provide, or that is generated, in subsequent email or telephone communications with us.

We do not actively collect personal data beyond the scope described in this section, and we do not collect special categories of data within the meaning of Article 9 GDPR (such as ethnic origin, political opinions, religious or philosophical beliefs, health, biometric or genetic data, sexual orientation, etc.).

4. Purposes and Legal Bases

We process your personal data only for the following purposes, relying on one of the legal bases under Article 6 GDPR:

• To respond to your inquiry, quotation request or cooperation intention (legal basis: performance of a contract / pre-contractual measures, Art. 6(1)(b); and legitimate interests, Art. 6(1)(f) GDPR).
• To maintain the security, stability and fault diagnosis of this website (legal basis: legitimate interests, Art. 6(1)(f) GDPR).
• To comply with applicable legal and tax obligations (e.g. books and records retention) (legal basis: legal obligation, Art. 6(1)(c) GDPR).
• Where you have given separate, explicit consent, to send you product/event updates or marketing communications (legal basis: consent, Art. 6(1)(a) GDPR; you may withdraw at any time).

We will not use your personal data for purposes incompatible with the above. If we intend to use it for a new purpose, we will inform you again and obtain your consent before doing so.

5. Data Recipients

We disclose your personal data only to the extent necessary to the following recipients, who are bound by appropriate confidentiality and data-processing agreements:

• Service providers that supply hosting, CDN, email delivery and security services to operate this website (e.g. cloud providers, email service providers, anti-spam and anti-malware vendors).
• KONJA group affiliates, when you actively request local contact or support, so that a colleague in the corresponding region can serve you.
• Competent judicial or administrative authorities, where required by applicable law or by a lawful request.
• Counterparties in a merger, acquisition or asset sale (we will notify you and require the recipient to continue protecting your data on terms no less protective than this policy).

We do not sell or rent your personal data to third parties, nor do we permit the above recipients to use your data for their own purposes.

6. International Data Transfers

To provide consistent global support, your personal data may be transferred to countries/regions outside your own, including without limitation to mainland China where KONJA Headquarters is located.

For transfers to third countries within the meaning of Articles 44 et seq. GDPR, we ensure the legality of the transfer by one of the following mechanisms:

• The recipient’s country/region is recognized by the European Commission as providing an adequate level of data protection; or
• By signing the European Commission’s Standard Contractual Clauses (“SCC”), supplemented by necessary technical and organisational measures; or
• Where you have given specific, explicit consent to a particular transfer (you may withdraw at any time).

You may obtain a copy of the transfer mechanism we rely on and the related supplementary measures by writing to Data protection contact.

7. Data Retention

We retain your personal data only for the minimum period necessary to fulfil the purposes described in Section 4 of this policy. Specifically:

• Inquiry/cooperation communication records: 24 months from the last interaction; if a business relationship is established, until the end of that relationship plus the applicable statutory period.
• Marketing subscriptions: processing stops immediately upon withdrawal of consent or unsubscribe; deletion or anonymisation is completed within 30 days.
• Server access logs: retained for no more than 12 months, for security audit and fault diagnosis.
• Data required to comply with legal obligations (e.g. tax, books and records) is retained in accordance with the retention periods prescribed by local law.

After the retention period expires, we will delete or anonymise the relevant data so that it can no longer identify you.

8. Your Rights

Under GDPR, you have the following rights with respect to your personal data:

• Right to be informed & right of access (Art. 13–15): to be informed about the processing and to obtain a copy of your personal data.
• Right to rectification (Art. 16): to require us to correct inaccurate or incomplete data.
• Right to erasure / right to be forgotten (Art. 17): to require us to delete your data in the cases provided by law.
• Right to restriction of processing (Art. 18): to require us to suspend processing while retaining the data itself in certain cases.
• Right to data portability (Art. 20): to receive the data you have actively provided in a structured, commonly used, machine-readable format and, where technically feasible, to have it transmitted directly to another controller.
• Right to object (Art. 21): to object, on grounds relating to your particular situation, to processing based on legitimate interests, including profiling related to direct marketing.
• Right not to be subject to a decision based solely on automated processing (Art. 22): not to be subject to a decision based solely on automated processing (including profiling) that produces legal or similarly significant effects on you.
• Right to withdraw consent (Art. 7(3)): where processing is based on consent, you may withdraw it at any time; withdrawal does not affect the lawfulness of processing before withdrawal.
• Right to lodge a complaint with a supervisory authority (Art. 77): you have the right to lodge a complaint with the supervisory authority of your habitual residence, place of work or place of the alleged infringement.

To exercise any of the above rights, please contact us at Data protection contact. We will respond within one month of receiving your request; where the request is complex or numerous, we may extend the period by a further two months and will inform you of the reasons within the first month. We do not generally charge for responding, but we may charge a reasonable fee or refuse to act on manifestly unfounded or excessive requests, as permitted by law.

9. Data Security

We implement technical and organisational measures appropriate to the risks of processing to protect your personal data against unauthorised or unlawful access, disclosure, alteration, destruction or loss, including but not limited to: transport-layer encryption (HTTPS/TLS), access control, least-privilege, log auditing, confidentiality obligations of personnel, and regular security reviews.

However, please understand that the Internet itself carries risks that we cannot control. Although we will continuously maintain reasonable security measures, we cannot guarantee the absolute security of information transmitted through this website or otherwise over the Internet. Any transmission of information is at your own risk.

10. Automated Decision-Making and Profiling

We do not make decisions about you based solely on automated processing of your personal data (including profiling) that produce legal or similarly significant effects on you. If we plan to do so in the future, we will notify you in a prominent manner in advance and, in accordance with Article 22 GDPR and applicable law, obtain your explicit consent or provide appropriate safeguards.

11. Cookies and Similar Technologies

When you visit this website, we only use cookies that are strictly necessary to provide basic functions and security. We will not write any non-essential cookies to your device, nor use them for commercial advertising or cross-site behavioural analysis, without your prior consent.

• Strictly necessary cookies: for session persistence, load balancing and anti-CSRF; disabling them will prevent the forms from functioning properly.
• We currently use no analytics or marketing cookies. If we do so in the future, we will request your consent again through a cookie banner.

You may clear stored cookies at any time via your browser settings, or enable the “Do Not Track” signal in your browser. Clearing strictly necessary cookies may affect your use of the website’s functions.

12. Third-Party Links

For your convenience, this website may contain links to third-party sites. Such links do not constitute our commitment to or endorsement of the content of the linked site, and we assume no responsibility for their content, data processing activities or privacy practices. We recommend that you review the privacy policy of any third-party site you visit.

13. Website Messages

您在本网站发布的任何侮辱、诽谤、淫秽或其他违反适用法律法规的内容，由您本人承担相应责任。我们对此不承担责任，并保留删除上述内容的权利。

If any message you post on this website is insulting, defamatory, obscene or otherwise in violation of applicable laws and regulations, you will be held solely responsible. We assume no responsibility and reserve the right to delete such messages.

14. Anti-Spam Commitment

We pursue a no-spam policy and take necessary measures to prevent spam. In particular, we undertake:

• Never to sell or rent personal data of users, potential users or website visitors.
• To send emails only to those who have agreed to receive them; you may unsubscribe at any time via the unsubscribe link in the message or via the contact channels at the end of this policy.
• To strengthen spam monitoring and take necessary preventive and remedial measures.

15. Limits of Liability

For losses caused by reasons beyond our reasonable control, including force majeure, government actions, and power or telecommunications interruptions, we do not bear relevant legal liabilities. We shall not be liable for any indirect losses or anticipated benefits arising from the use of this website or its content, including but not limited to loss of profits, loss of contractual opportunities, litigation costs, incidental expenses, special expenses or other similar incidental damages.

16. Complaints and Supervisory Authority

If you believe that our processing of your personal data infringes GDPR or other applicable data-protection laws, you have the right to lodge a complaint with the Data Protection Authority (DPA) of the Member State of your habitual residence, place of work or place of the alleged infringement. The contact details of the lead DPA for the Data Controller’s Member State are:

• DPA Name:
• Address:
• Website:
• Phone / Email:

We encourage you to contact us first so that we can respond to and address your concerns as quickly as possible.

17. Notices and Amendments

We reserve the right to change, upgrade or modify this website at our sole discretion based on operational needs and user experience. At the same time, in order to provide better service and with the development of KONJA, this policy will be updated accordingly, and any relevant changes will be announced through this website. For material changes, we will provide additional notice in a reasonable manner (e.g. website announcement or email).

18. Governing Law and Dispute Resolution

The formation, validity, interpretation, performance of this policy and any dispute related thereto shall be governed by the laws of the EU Member State where the Data Controller is registered, together with GDPR. Any dispute relating to personal data processing shall be resolved primarily through amicable negotiation; if that fails, either party may bring an action before the competent court at the registered seat of the Data Controller, without prejudice to any mandatory consumer-protection laws that apply to you locally and without prejudice to your right to lodge a complaint with the competent DPA.

19. Contact Us

If you have any questions, comments or requests regarding this policy, the processing of your personal data, or your exercise of rights under GDPR, please contact us:

• Data protection contact:
• Data Controller address:
• KONJA Headquarters:

To protect your rights and your data, we may need to reasonably verify your identity before responding to your request.