Privacy Policy

1. Who we are

Midwel (Hangzhou Midwel Intelligent Technology Co., Ltd.) is a Chinese-registered company operating an authorized export office for aerosol products. We act as the data controller for any personal data collected through this website.

• Registered office: 8F, Building 1, Nanbei Shengde International, No.236 Tongyun Road, Yuhang District, Hangzhou, Zhejiang, China
• Contact: Ray@midwel.com · WhatsApp +86 159 9003 2296

2. What data we collect

Data	When	Why
Name, company, country, email	You submit a form (quote, sample, factory tour)	Reply to your inquiry, prepare quotation
Phone / WhatsApp	You choose to share it	Faster reply if you prefer voice/chat
IP address, browser, country	Every visit (server logs)	Security, fraud prevention, analytics
Pages viewed, click events	Google Analytics 4 (after consent)	Understand which content helps buyers
Form timestamp + submission content	When you submit any form	Track and reply to your request

We do NOT collect: payment card numbers, government IDs, biometric data, or any special-category data under GDPR Article 9.

3. How we use your data (legal bases)

• Pre-contractual steps (Art. 6(1)(b) GDPR): when you request a quote, sample, or factory tour, we use your contact data to reply and prepare the offer.
• Legitimate interest (Art. 6(1)(f) GDPR): basic server logs, spam protection, and aggregated analytics to keep the site secure and useful.
• Consent (Art. 6(1)(a) GDPR): for non-essential cookies and marketing emails. You can withdraw consent at any time.
• Legal obligation (Art. 6(1)(c) GDPR): to keep invoices and export records for the period required by Chinese accounting law (10 years).

4. Cookies & third-party services

Service	Type	Purpose	Lifetime
WordPress-style session cookie	Essential	Form CSRF protection	Session
Google Analytics 4	Analytics (consent-gated)	Understand site usage	13 months
Google Ads conversion	Marketing (consent-gated)	Measure ad effectiveness	90 days

You can refuse non-essential cookies through our cookie banner. Essential cookies cannot be disabled as they are required for the site to function.

5. Data sharing

We do not sell your data. We share it only with:

• Google LLC (Analytics, Ads) — for the purposes listed above. Data is transferred to the US under Standard Contractual Clauses.
• Our manufacturing partner — only the project specifications you chose to share, and only after you have confirmed an order.
• Logistics & customs agents — only the contact and shipping details required to deliver samples or commercial shipments.
• Government authorities — when legally required (customs, export licensing, anti-money-laundering).

6. International data transfers

Our servers are located in China. When you submit a form from outside China, your data is transferred to China. We rely on Standard Contractual Clauses and your explicit submission as the legal basis for such transfers. For EU/UK residents, you may request a copy of the safeguards we apply.

7. Retention

Data	Retention
Quote/sample inquiries (no order placed)	12 months from last contact
Customer order records	10 years (Chinese accounting law)
Server logs	90 days
Analytics data (aggregated)	14 months
Marketing email subscription	Until you unsubscribe

8. Your rights

Depending on your jurisdiction (GDPR / UK GDPR / CCPA / PIPL), you have the right to:

• Access the personal data we hold about you
• Correct inaccurate data
• Delete data (subject to legal retention obligations)
• Restrict or object to processing
• Receive a portable copy of your data
• Withdraw consent at any time (without affecting prior processing)
• Lodge a complaint with your local data protection authority

To exercise any of these rights, email Ray@midwel.com. We respond within 30 days.

9. Children

This site is not directed at children under 16. We do not knowingly collect data from children.

10. Changes to this policy

We may update this policy. The "Last updated" date at the top reflects the most recent change. Material changes will be communicated by a banner on the homepage for at least 14 days.

11. Contact

Questions about this policy or our data practices? Email Ray@midwel.com. We respond within 5 business days.