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⚠ DRAFT — pending legal review before publishing. This is a platform-level (Tech4Trade Limited / iOrderSmart) master Privacy Policy. It is not legal advice and has not been reviewed by counsel. Have it reviewed by Hong Kong counsel, and by local counsel (Mexico, EU, US, or elsewhere) for any Specific Service operating in that territory, before publishing anywhere.

Last drafted: 2026-09-01 · Supersedes: prior "iOSmart" Privacy Policy in this file. The prior version described features iOrderSmart does not have (Groups, Answers, InMail, public profiles, third-party ad networks, memorialized accounts) and named an inconsistent entity ("SBE International Holdings Limited"). This draft is rebuilt around what the Platform actually does, aligned with the Importa México Privacy Notice at importamexico.com.mx/en/privacidad/, which remains the binding, Mexico-specific document for that Specific Service.

This document is currently published in English only. Spanish and Chinese translations are pending.

iOrderSmart Privacy Policy

Highlights


1. Who this policy covers, and who is the Controller

This Privacy Policy is published by Tech4Trade Limited, a company incorporated in Hong Kong (Certificate of Incorporation No. 2148310, dated September 24, 2014), which owns and licenses the iOrderSmart software (the "Platform").

iOrderSmart is deployed through branded, region-specific Specific Services operated by other members of the iOrderSmart Group (for example, Importa México, operated by Soluciones Integrales G1S, S. de R.L. de C.V., representing GIS Holdings Limited, Hong Kong). For each Specific Service:

If a Specific Service you use has its own published Privacy Notice, that notice is the legally binding document for your relationship and prevails over this general policy on any point specific to that service (contact details, local legal basis, regional rights such as Mexico's ARCO rights or the EU's GDPR rights, retention periods tied to local law, and similar). Where no Specific Service notice exists, or on matters not addressed there, this policy applies, with Tech4Trade Limited as the responsible party.

How to find your Controller: check the footer of the site you registered on, or contact it@iordersmart.com and we will direct you to the correct entity and notice.

2. What information we collect

Depending on how you use the Platform, we may process:

We do not intentionally collect sensitive personal data. If a document you upload contains a third party's personal or sensitive data, you represent that you are authorized to share it with us for the purposes described in this policy.

3. Your obligations regarding data you provide

4. Use of Artificial Intelligence

The Platform's AI features (branded Nova on most deployments) process the text, documents, and data you submit to them. In summary:

Full detail — including current model providers, retention, and how to raise a concern about AI data handling — is in the standalone AI Use Policy, which forms part of this Privacy Policy by reference.

5. Why we use your information (purposes)

We do not sell, rent, or otherwise provide your personally identifiable information to third parties for marketing purposes.

6. Who we share your information with

We share data only as necessary to provide the Platform, with recipients acting under confidentiality and security obligations:

We do not sell your personal data.

7. Your rights and choices

Depending on where you or your company are located, you may have some or all of the following rights over your personal data, exercisable by contacting us (§10) or your Specific Service's Controller:

We will respond to a verified request within the timeframe required by applicable law (for example, 30 days under Mexican law absent an extension).

You can review and update most account and company information directly from your account settings. You may close your account at any time by contacting us; we will delete or de-identify your data within a reasonable period, except data we are required to retain by law (for example, tax, customs, or accounting retention obligations) or that is necessary to resolve disputes or enforce our agreements.

8. Children

Our services are intended for business use by adults. We do not knowingly collect personal data from minors under 18, and ask that minors not submit personal information to us or use the Platform.

9. Security

We apply administrative, technical, and physical safeguards appropriate to the sensitivity of the data involved, including role-based access control, encryption in transit for sensitive data, and regular review of our systems for vulnerabilities. No method of transmission or storage is 100% secure, and we cannot guarantee absolute security. You are responsible for safeguarding your account credentials and for controlling who has access to your email and messaging accounts. Emails, chat, and similar messages within the Platform are not end-to-end encrypted; avoid sending highly sensitive information (e.g., full payment card numbers) through these channels.

10. Changes to this Policy; how to contact us

We may update this Privacy Policy to reflect legal, operational, or product changes. Material changes will be posted here, and, where required, notified by email or an in-product notice. Continued use of the Platform after such notice constitutes acceptance of the updated policy, to the extent permitted by applicable law.

Questions, requests, or complaints about this Policy: it@iordersmart.com, or the contact address published by the relevant Specific Service (see §1).