Privacy Policy

X Silence International Technology Trade Co., Limited

Last Updated: July 19, 2026

 

1. Who We Are & Data Controller

This website is operated by X Silence International Technology Trade Co., Limited, a limited company incorporated in Hong Kong SAR (“we”, “us”, “our”).

• Registered Address: RM 18 2/F, TUSPARK, 118 WAI YIP STREET, KWUN TONG HONG KONG
• Official Contact Email: info@xsittmj.com
• Contact Phone: +86 13066162969
• Business Scope: B2C retail of ready-made mahjong gift sets, B2B OEM & ODM bespoke custom mahjong design, brand packaging customization, mass wholesale supply, and craftsmanship supporting services.

We act as the sole Data Controller for all personal information collected through this website, Meta (Facebook & Instagram) advertising campaigns, lead ad forms, inquiry and checkout pages.

 

This Privacy Policy complies with four core regulatory frameworks:

1. Hong Kong Personal Data (Privacy) Ordinance (PDPO, Cap.486)
2. California Consumer Privacy Act / CPRA (CCPA, for all US California customers & visitors)
3. EU General Data Protection Regulation (GDPR, applicable to EU & UK visitors)
4. Meta Platforms (Facebook & Instagram) Advertiser Data & Pixel Compliance Rules

This policy applies to all site visitors, individual retail shoppers (B2C), wholesale distributors, OEM/ODM custom clients, and users who interact with our social media ads.

 

2. Personal Information We Collect

We split collected data into voluntarily submitted information and automatically captured technical data, distinguishing B2C retail users and B2B wholesale partners separately.

2.1 Information You Voluntarily Submit

A. B2C Individual Retail Customers

• Full name, shipping address, postal code, contact phone number, personal email address
• Order records, payment transaction details, gift customization notes
• Website account username and encrypted login password
• Product review text, photos uploaded for feedback
• Marketing newsletter opt-in / opt-out preferences
• Information submitted via Facebook & Instagram lead ads for retail inquiries

B. B2B Wholesale & OEM/ODM Custom Partners

• Corporate name, buyer contact full name, job title, business email, business telephone
• Company registered address, MOQ demands, custom pattern & packaging requirements
• Uploaded brand logos, trademark drafts, exclusive mahjong artwork and design files
• Sample order records, mass production quotation data, contract review materials
• CPSC certification relevant business documents submitted for custom production

C. Meta Ads Lead Form Data

When you fill out instant inquiry forms on our Facebook or Instagram advertisements, we collect your submitted name, email, phone number and custom project demands solely for quotation and follow-up communication.

2.2 Automatically Collected Technical Information

• Device identifiers: IP address, browser type & version, operating system, screen resolution
• Website behavioral data: browsing pages, search keywords, click paths, dwell time
• Tracking signals from Google Analytics 4 and Meta (Facebook/Instagram) Pixel
• Traffic referral sources (Facebook, Instagram, Google search, direct entry, external links)
• Cookie consent status and site preference records

3. Legal Basis & Purposes of Data Usage

We process your personal data under lawful grounds including contract performance, legitimate business interest, and your explicit opt-in consent only. All data is used strictly for the purposes stated below:

1. Fulfill B2C retail orders: process secure payments, arrange international shipping, deliver mahjong sets, handle after-sales repair, replacement and customer support
2. Deliver B2B custom OEM/ODM services: communicate your design demands, develop engineering drawings, produce pre-production samples, arrange bulk manufacturing, review cooperation contracts
3. Legal & tax compliance: retain complete business records to satisfy Hong Kong tax and accounting statutory requirements, apply US CPSC safety certifications for custom mahjong products
4. Daily customer support: reply email inquiries, resolve order disputes, provide mahjong maintenance guidance
5. Marketing & Meta social advertising: send new product releases and wholesale quotations only to users who explicitly subscribed; deploy Meta Pixel and GA4 to measure ad conversion, optimize Facebook/Instagram targeting and remarketing audiences
6. Website experience optimization: analyze visitor browsing habits to refine page layout, search function and user journey
7. Risk & fraud prevention: detect spam comments, unauthorized account login, fake orders and malicious site access

Exclusive Confidential Commitment for B2B Custom Design Files

All client uploaded logos, proprietary mahjong patterns, artwork drafts and brand design materials shall only be used to manufacture goods under your current order. Without a signed written intellectual property buyout agreement from your side, we will never disclose, resell, copy or reuse your exclusive designs for third-party commercial orders.

4. Cookies & Meta Pixel Tracking Technology

We deploy four categorized cookie groups on our website, fully aligned with Meta advertising consent rules, GDPR and CCPA standards. A consent pop-up banner will display upon your first site visit to let you accept or reject non-essential tracking cookies:

1. Essential Cookies: Mandatory core cookies for shopping cart, checkout, login and form submission. Cannot be disabled as the website cannot function normally without them.
2. Functional Cookies: Store your language, screen display and privacy consent preferences, valid for 12 months.
3. Analytics Cookies (Google GA4): Collect anonymous traffic statistics to optimize website performance.
4. Marketing Tracking Cookies (Meta Facebook / Instagram Pixel): Capture conversion events from our social ads, build targeted remarketing audiences on Meta platforms. If you opt out marketing tracking, Meta Pixel will stop collecting your behavioral data for Facebook & Instagram ad targeting.

Embedded third-party content (social share buttons, embedded videos) may deploy independent tracking cookies governed by their own privacy policies.

5. Third Parties We Share Your Personal Data With

We will never sell your personal information to unrelated third parties for monetary profit. We only disclose limited necessary data to trusted service providers bound by formal confidentiality agreements:

1. Payment Processors: PayPal, Stripe (PCI-DSS compliant platforms handling all credit card and online order payments; we do not store full card details)
2. Global Logistics & Freight Forwarders: Deliver retail and bulk wholesale goods to destinations across the United States and worldwide
3. Analytics & Advertising Platforms: Google (GA4), Meta Platforms (Facebook & Instagram Pixel, lead ad data storage)
4. Email Marketing Service Providers: Send order updates, retail promotions and wholesale quotations to subscribed users
5. Website Hosting & Technical Support Vendors: Securely store website data and maintain server operation
6. Authorized Manufacturing Partners in Mainland China: Only receive your custom design and order information to produce OEM/ODM goods; prohibited from using your proprietary brand materials for any external business
7. Mandatory Legal Disclosure: We may release your personal data when required by Hong Kong courts, U.S. federal/state law enforcement, tax authorities or official regulatory investigations.

6. Cross-Border Data Transfer

Your personal information will be stored and processed across multiple regions including Hong Kong, Mainland China, the United States and EU server locations.

 

For users protected under GDPR and Hong Kong PDPO: We adopt EU-approved Standard Contractual Clauses (SCCs) to guarantee cross-border data protection standards equivalent to local privacy laws. All overseas third-party data processors are bound by strict written confidentiality obligations.

7. Data Retention Period

We only retain your personal data for the minimum period required to fulfill the original collection purposes:

1. B2C retail orders, payment and delivery records: Retained for 7 years to meet Hong Kong statutory tax retention requirements
2. B2B OEM/ODM design files, cooperation contracts, sample and bulk order documents: Retained for 7 years after the end of business cooperation
3. Marketing email subscription data: Stored permanently until you submit an unsubscribe request
4. Website browsing cookie tracking behavioral data: Automatically deleted within 12 months
5. Registered user account and comment data: Saved until you submit a full erasure request, excluding records we must retain to satisfy legal compliance obligations

After the retention period expires, all personally identifiable information will be permanently anonymized or fully deleted from our systems.

8. Your Legal Privacy Rights

8.1 Rights under Hong Kong PDPO (Applicable to All Global Users)

1. Right of Access: Request a complete copy of all personal data we hold related to you
2. Right of Correction: Amend inaccurate name, address, corporate or order information
3. Right of Erasure: Submit a formal request to delete your personal data (excluding records required by law)
4. Right to Object Direct Marketing: Unsubscribe from all promotional emails at any time free of charge
5. Right to Lodge Formal Complaints: You may submit privacy disputes to the Hong Kong Office of the Privacy Commissioner for Personal Data (PCPD)

8.2 Rights under CCPA (For California US Residents)

1. Right to Know: Request full disclosure of all categories of personal data we have collected, used and shared about you
2. Right to Delete: Demand permanent removal of your personal identifiable information
3. Right to Opt-Out of Cross-Context Targeted Advertising: Contact info@xsittmj.comto stop Meta and Google ad tracking based on your website browsing behavior
4. Non-Discrimination Protection: We will not raise product prices, restrict service access or provide different service levels if you exercise your CCPA privacy rights
5. We do not sell your personal information as defined under official CCPA regulations.

8.3 Rights under GDPR (For EU & UK Visitors)

You hold full standard GDPR data subject rights including data processing restriction, data portability, and the right to object to processing based on legitimate business interest.

How to Exercise All Privacy Rights

Send a clear written request email to info@xsittmj.com with your full matching name and contact information for identity verification. We will respond to all valid privacy requests within 30 calendar days as required by global privacy laws.

9. Data Security Protection

We deploy industry-standard security measures to protect your personal data during transmission and storage:

• SSL encrypted transmission for all payment and form submission channels, fully PCI-DSS compliant
• Password encrypted cloud storage for confidential B2B custom design files
• Tiered internal staff access permission control; only designated operation teams can view customer order and business information
• We will notify affected users and relevant regulatory authorities promptly if any confirmed personal data security breach occurs, in full compliance with legal notification deadlines.

10. Children’s Privacy Protection

Our website, Facebook and Instagram advertising content target adult retail consumers and corporate wholesale business clients only. We do not knowingly collect personal information from users under 16 years old. If you believe we have obtained minor personal data without legal guardian consent, please contact info@xsittmj.com for immediate permanent deletion of all relevant records.

11. Modifications to This Privacy Policy

We reserve the right to update this Privacy Policy to match changes in our business services, Meta advertising tools or updated global privacy regulations. All revised policy versions will be published on this dedicated page with an updated effective date. Your continued website browsing, order placement or interaction with our Facebook & Instagram ads after policy updates confirms your acceptance of the revised terms.

12. Privacy Inquiry Contact Information

For all privacy-related requests, complaints or clarification about Facebook/Instagram ad data tracking rules:

 

Official Email: info@xsittmj.com

 

Contact Phone: +86 13066162969

 

Company Legal Entity: X Silence International Technology Trade Co., Limited

 

Hong Kong Registered Address: RM 18 2/F, TUSPARK, 118 WAI YIP STREET, KWUN TONG HONG KONG