Privacy Policy
Last updated: 27 October 2026
Up2China helps international brands enter and grow in the Chinese market. We take the privacy of the people who visit our website and work with us seriously. This Privacy Policy explains what personal information we collect, why we collect it, how we use and share it, and the choices and rights you have.
We have written this policy to meet the requirements of the EU and UK General Data Protection Regulation (GDPR), the Personal Information Protection Law of the People’s Republic of China (PIPL), and other applicable privacy laws.
1. Who We Are
This website, www.up2china.com, is operated by Telino Innovation Ltd. (“Up2China”, “we”, “us” or “our”). Up2China is the controller (under the PIPL, the “personal information handler”) responsible for the personal information described in this policy.
Registered address: Room 1005, 10th Floor, Building 3, No. 58 Zhida 2nd Road, Wuhou District, Chengdu, Sichuan, People’s Republic of China (四川省成都市武侯区智达二路58号3栋10层1005号).
Office address: Block D, Jiaozi Financial Technology Center, Wuhou District, Chengdu, Sichuan, People’s Republic of China (四川省成都市武侯区交子金融科技中心D栋).
Privacy contact: Info@up2china.com
2. Scope of This Policy
This policy applies to personal information we collect through our website, our consultation booking tools, our email communications, and our business dealings with prospective and existing clients, partners and suppliers.
It does not apply to personal information that we process on behalf of our clients when delivering services (for example, e-commerce store operations, customer service or CRM work for a client brand). In those cases our client is the controller, and we act as a processor (under the PIPL, an “entrusted party”) following our client’s instructions. Our handling of that data is governed by our service agreement and any data processing terms agreed with the client.
Our website may contain links to third-party websites and platforms, such as social media pages and e-commerce marketplaces. We are not responsible for the privacy practices of those third parties, and we encourage you to read their privacy policies.
3. Personal Information We Collect
3.1 Information you give us
- Contact form: your full name, company name, business email address, the subject of your enquiry, your message, and whether you chose to join our mailing list.
- Consultation bookings: when you book a strategy call through our online scheduling tool, your name, email address, the time slot you choose and any answers you provide about your business and goals.
- Correspondence: information you share when you email, call or message us (including via WeChat, LinkedIn or other platforms), such as your job title, phone number and project details.
- Client and partner relationships: business contact details and information needed to prepare proposals, contracts and invoices, and to deliver our services.
3.2 Information we collect automatically
When you visit our website, we and our technology partners automatically collect certain information, including your IP address, approximate location (country/city), browser and device type, operating system, language, referring website, the pages you view and how long you spend on them, the links and buttons you click, and the marketing campaign or channel that brought you to our site. Some of this information is collected using cookies and similar technologies (see Section 6).
3.3 Information from other sources
We may receive business contact information from publicly available sources (such as company websites and professional networks like LinkedIn), from event organisers, and from partners who introduce you to us. We also receive aggregated reports from advertising and analytics platforms.
3.4 Sensitive personal information
We do not intentionally collect sensitive personal information (for example, health, biometric, religious or financial account information) through our website. Please do not include such information in messages to us.
4. How We Use Your Information and Our Legal Bases
We only use your personal information where we have a lawful basis to do so. The table below explains our purposes and the legal basis we rely on for each.
| Purpose | Examples | Legal basis |
|---|---|---|
| Responding to your enquiry | Replying to contact form messages, emails and calls | Our legitimate interest in answering business enquiries; or, where you contract with us personally, steps taken at your request before entering into a contract |
| Consultations and proposals | Scheduling and holding strategy calls; preparing quotes and proposals | Our legitimate interest in developing business with your company; or, where you contract with us personally, steps taken at your request before entering into a contract |
| Delivering our services | Managing client projects, communication, invoicing and support | Performance of a contract where you are our contracting party; otherwise our legitimate interest in managing our relationship with the client company you represent |
| Marketing communications | Sending reports, updates and news to subscribers | Your consent, which you can withdraw at any time |
| Website analytics and improvement | Understanding which pages and content are useful; measuring campaign performance | Your consent where required by law; otherwise our legitimate interest in improving our website |
| Advertising | Measuring the results of our ads and showing relevant ads on other platforms | Your consent |
| Security and fraud prevention | Blocking spam submissions and protecting our website | Our legitimate interest in keeping our website and business secure |
| Legal and compliance | Keeping business and tax records; responding to lawful requests | Compliance with legal obligations |
Most of our clients are companies. If you contact us or work with us on behalf of your employer or another organisation, the contract is with that organisation, not with you personally. In that case we process your business contact details on the basis of our legitimate interest in communicating and doing business with that organisation.
Where we rely on legitimate interests, we have balanced those interests against your rights and freedoms. Where we rely on consent, you may withdraw it at any time; this will not affect processing carried out before you withdrew it. Under the PIPL, we process personal information on the basis of your consent, or where it is necessary to conclude or perform a contract to which you are a party, or on another basis permitted by law.
We use the details you send through our contact form and booking tool only to reply to you and to follow up on your enquiry. We do not add you to our mailing list unless you ask us to, and we never sell or rent your details.
We do not use your personal information for automated decision-making that produces legal or similarly significant effects on you.
5. How We Share Your Information
We do not sell your personal information. We share it only as described below:
- Service providers who help us run our website and business, such as website hosting and content delivery, email delivery, online scheduling, analytics, advertising measurement and office/productivity software. Some of these providers act only on our instructions (for example, hosting and email delivery). Others, in particular advertising and analytics platforms such as Google and Meta, may also use certain information for their own purposes, as described in their own privacy policies.
- Platform and agency partners (for example, e-commerce platforms or local service partners in China) where this is necessary to deliver a service you have asked for, and with your agreement where required.
- Professional advisers such as lawyers, accountants and auditors, under duties of confidentiality.
- Authorities where we are required to do so by law, regulation or legal process, or to protect our rights, property or safety and those of others.
- Business transfers: in connection with a merger, acquisition, reorganisation or sale of assets, subject to this policy.
6. Cookies and Similar Technologies
Cookies are small text files placed on your device when you visit a website. We and our partners use cookies, pixels and similar technologies for the purposes below.
| Category | What it does | Provider / examples |
|---|---|---|
| Strictly necessary | Required for the website to work securely, including spam protection on our forms. These cannot be switched off. | Up2China (WordPress) |
| Tag management | Loads and manages the other analytics and advertising tags on our website. It does not itself build a profile of you. | Google Tag Manager (Google) |
| Analytics | Helps us understand how visitors use our site, which pages are popular and where visitors come from. | Google Analytics 4 (Google) |
| Attribution | Remembers how you first and most recently arrived at our site (for example, from a search engine or a campaign) so that we can understand which channels work. | Up2China first-party cookies: u2c_first and u2c_last (each kept for 180 days) |
| Advertising | Measures the effectiveness of our ads and allows us to show relevant ads to visitors on other platforms. | Meta Pixel (Meta Platforms); Google Ads conversion tracking (Google) |
| Functional | Enables features you choose to use, such as booking a call, sharing a page or translating the site. | Calendly; AddToAny; GTranslate |
A full list of the cookies we use, with their names, providers, purposes and expiry periods, is available in the cookie settings on our website.
When you first visit our website, a cookie banner asks for your choice. Strictly necessary cookies are always active. All other cookies (analytics, attribution, advertising and functional cookies from third parties) are only set after you agree. You can change or withdraw your choice at any time through the cookie settings link on our website.
You can control or delete cookies through your browser settings, and you can opt out of Google Analytics by installing Google’s opt-out browser add-on. Where we ask for your consent to cookies, you can change your choice at any time. Blocking some cookies may affect how parts of our website work.
Our website does not currently respond to “Do Not Track” signals.
7. International Transfers
Up2China is based in the People’s Republic of China, and our clients are mainly located outside China. Information you send us through our contact form or by email is received by our team in China. Our main service providers that receive personal information are located outside China, mainly in the United States:
- Google (United States): website analytics (Google Analytics), tag management and advertising measurement. Information: device, browser and usage data, approximate location and cookie identifiers.
- Meta Platforms (United States): advertising measurement (Meta Pixel). Information: device and usage data and cookie identifiers.
- Calendly (United States): booking consultation calls. Information: your name, email address, chosen time slot and any answers you give.
As a result, your personal information may be transferred to, stored in and accessed from countries other than the one in which you live, including China and the United States.
- From the EEA, UK or Switzerland: where we transfer personal information to a country that has not been recognised as providing an adequate level of protection, we rely on the safeguards in our service providers’ data processing terms, which incorporate the European Commission’s Standard Contractual Clauses (and, for the UK, the UK Addendum), or on another mechanism permitted by law.
- From mainland China: where personal information collected in China is provided to recipients outside China, we do so in accordance with the PIPL and related regulations. The list above tells you who the overseas recipients are, what they receive and why. Where the law requires your separate consent, we will ask for it.
You can contact us for more information about the safeguards we use.
8. How Long We Keep Your Information
We keep personal information only for as long as necessary for the purposes described in this policy, unless a longer period is required or permitted by law. As a general guide:
- Enquiries and consultation requests that do not lead to a business relationship: for as long as needed to respond to and follow up on your enquiry. We review these records at least once a year and delete those we no longer need.
- Client and supplier records: for the duration of our relationship and afterwards for the period required by applicable accounting, tax and legal requirements.
- Mailing list: until you unsubscribe or ask us to delete your details. After you unsubscribe, we keep a minimal record (your email address and the date you unsubscribed) so that we do not send you marketing emails again.
- Website analytics data: Google Analytics keeps user-level and event-level data for 14 months, after which it is deleted automatically.
When information is no longer needed, we delete it or anonymise it so that it can no longer be linked to you.
9. How We Protect Your Information
We use reasonable technical and organisational measures to protect personal information against loss, misuse, unauthorised access, disclosure and alteration. These include encrypted connections (HTTPS), access controls limited to staff who need the information, spam and abuse protection on our forms, and confidentiality obligations for our staff and service providers. No method of transmission over the internet is completely secure, but we work to protect your information and will notify you and the relevant authorities of a personal information security incident where required by law.
10. Your Rights
Depending on where you live, you may have some or all of the following rights over your personal information:
- to be informed about and to access the personal information we hold about you and receive a copy of it;
- to have your personal information transferred to another personal information handler designated by you, where the conditions set by the Cyberspace Administration of China are met (PIPL);
- to correct or complete inaccurate or incomplete information;
- to delete your personal information;
- to restrict or object to our use of your information, including for direct marketing;
- to data portability, meaning to receive your information in a structured, commonly used format or have it transferred to another organisation where technically feasible;
- to withdraw your consent at any time;
- to request an explanation of our rules for processing personal information (PIPL);
- where a person has passed away, for their next of kin to exercise certain of these rights over the deceased person’s information for their own lawful and legitimate interests (PIPL);
- not to be discriminated against for exercising your privacy rights.
To exercise any of these rights, please email us at Info@up2china.com with the subject line “Privacy Request”. We may need to verify your identity before responding. We will respond within one month (or any other time required by applicable law). You may also authorise an agent to make a request on your behalf, subject to verification.
If you are in the EEA or UK, you also have the right to lodge a complaint with your local data protection supervisory authority. We would, however, appreciate the chance to address your concerns first, so please contact us.
11. Marketing Communications
We only send marketing emails, such as reports and industry updates, to people who have opted in, for example by ticking the mailing list box on our contact form. Every marketing email includes an unsubscribe link, and you can also unsubscribe at any time by emailing Info@up2china.com. We will still send you service-related messages where necessary. After you unsubscribe, we keep a minimal record of your email address so that we do not send you marketing emails again.
12. Children’s Privacy
Our website and services are intended for businesses and professionals. They are not directed at anyone under the age of 18, and we do not knowingly collect personal information from anyone under 18. If you believe a child has provided us with personal information, please contact us and we will delete it.
13. Changes to This Policy
We may update this Privacy Policy from time to time to reflect changes in our practices, technologies or legal requirements. We will post the updated version on this page and change the “Last updated” date above. We review this policy at least once a year. If the changes are significant, we will take reasonable steps to let you know before they take effect.
14. Governing Law and Language
This Privacy Policy is governed by the laws of the People’s Republic of China, without prejudice to any mandatory data protection rights you have under the laws of the country where you live. If we publish this policy in more than one language and the versions differ, the English version prevails.
15. Contact Us
If you have any questions about this Privacy Policy or how we handle your personal information, please contact us:
Telino Innovation Ltd.
Registered address: Room 1005, 10th Floor, Building 3, No. 58 Zhida 2nd Road, Wuhou District, Chengdu, Sichuan, China
Office address: Block D, Jiaozi Financial Technology Center, Wuhou District, Chengdu, Sichuan, China
Email: Info@up2china.com