HubBuyer Huaban Member Referral Program Privacy Policy

Revision Date: August 20, 2026

Version: v1.0

Publication/Effective Date: Effective August 20, 2026 (on first publication, the effective date should match the publication date)

This Policy applies to applicants for the Huaban Member Referral Program, Referral Members, users who access or register through referral links, QR codes, or referral codes, and natural persons related to referral attribution, rewards, and settlement. The Program operator, general information processing rules, security measures, and privacy contact channels are governed by the HubBuyer Global Privacy Policy.

Relationship with the Main Privacy Policy and Terms of Service

This Policy applies together with the HubBuyer Global Privacy Policy. This Policy explains processing specific to the referral program. Account, order, payment, warehousing, logistics, cross-border, security, user rights, and policy update matters not covered here are governed by the main privacy policy.

Commercial rules for Referral Member eligibility, attribution, Qualified Orders, reward amount, settlement, violation handling, and termination are governed by the HubBuyer Huaban Member Referral Program Terms and the current program page. This Policy does not independently create any reward or payment right.

If a Referral Member independently determines the purposes and means of collecting or using others' information for its own promotional activities, the member is responsible for those activities. The Platform is responsible under this Policy and applicable law for processing where it independently determines the purposes and means to operate the referral program.

Information We May Process

Referral Member account and review information: name or business name, country or region, phone, email, login credentials, agreement records, promotion channels, website or social account, and proof materials submitted when required for identity, business authorization, settlement, tax, risk control, or law.

Referral and attribution information: Referral Member ID, exclusive link, QR code or referral code parameters, click and registration time, source page, campaign identifier, cookie or local storage identifier, IP address, device and browser information, registration or binding status, and attribution change records.

Referred user and order status: de-identified user identifier, country or region, registration and review status, activation, renewal, or valid status of applicable services, Qualified Order date or de-identified order number, reward calculation basis, and payment, cancellation, refund, chargeback, dispute, or invalidation status.

Reward and settlement information: promotion level, reward type, ratio or amount, status, settlement cycle, withdrawal application, payee, bank or payment account, currency, exchange rate, fees, tax residence, tax number, invoice, withholding tax, and payment records. Bank or payment accounts, tax numbers, and identity documents are sensitive personal information. The Platform processes them only as necessary for settlement, tax, and compliance, and obtains your separate consent prominently at collection.

Promotion, communication, and compliance information: promotion channels and content, use of Platform materials, disclosure of interest relationship, customer service communications, complaints, appeals, evidence, and review records related to brand, anti-spam marketing, intellectual property, or other promotion rules.

Security and anti-cheating information: account, device, IP, or payment associations, abnormal clicks or registrations, self-referrals, duplicate attribution, false orders, refunds and chargebacks, link misuse, non-compliant promotion, account restrictions, and investigation results.

Information Sources, Purposes, and Necessity

Information may be provided directly by Referral Members, business authorized personnel, or referred users; generated automatically when using websites, referral entry points, accounts, and orders; or provided by HubBuyer account and transaction systems, banks or payment providers, technical and security providers, and other lawful sources.

We mainly process information to review and manage referral accounts; generate referral entry points; confirm referral source and single attribution; determine Qualified Referrals and Qualified Orders; calculate, confirm, pay, revoke, or recover rewards; handle reconciliation, taxes, complaints, and disputes; send account, reward, and settlement notices; identify cheating; protect system and transaction security; improve the Program; and comply with legal obligations. With your consent or where applicable law allows, the Platform may also send Program-related campaign or marketing information, which you may opt out of at any time through the unsubscribe method in the message or official channels.

Depending on the scenario, processing may be based on entering into or performing a contract, complying with legal obligations, protecting account and transaction security, your consent, or another lawful basis. Where extraterritorial laws such as the GDPR apply, some processing may also be based on legitimate interests. If applicable law requires consent, separate consent, or another specific procedure, the Platform will handle it in the relevant scenario.

If information necessary for application review, referral attribution, reward verification, or settlement is not provided, the Platform may be unable to open a referral account, identify the referral relationship, confirm rewards, or complete payment. Failure to provide optional information affects only the relevant optional function.

Referral Links, Cookies, and Attribution

When a user visits HubBuyer through a referral link, QR code, or referral code, link parameters, cookies, local storage, or similar technologies may record the Referral Member ID, click time, source page, campaign, and device information to confirm referral source, calculate rewards, measure performance, and prevent cheating.

Specific attribution period, touchpoint priority, relationship between referral codes and links, binding conditions, and Qualified Order requirements are governed by the referral program rules and system records. To handle duplicate referrals, parameter abnormalities, or cheating risks, the Platform may verify attribution using registration, order, device, and other reasonable records.

Where applicable law requires, non-essential attribution, advertising, or measurement technologies will be enabled only after the required choice or consent is obtained. If a user refuses or clears cookies, accesses across devices, uses privacy tools, the entry point expires, or registers through another channel, the Platform may be unable to confirm the referral relationship or calculate related rewards, but the user's use of core HubBuyer services is unaffected.

Some attribution and analytics technologies may be provided by third parties and governed by their rules. Where applicable law requires, the Platform will provide necessary information through cookie notices, relevant pages, or supplemental explanations. The Platform will list the types, purposes, and periods of cookies and similar technologies on the cookie notice or settings page and provide available management options.

Referred User Information and Referral Member Visibility

To verify referrals and rewards, the Referral Member dashboard displays only de-identified user identifiers, binding time, applicable service status, Qualified Order status, reward calculation basis, and reward results related to that member's promotion. The Platform may adjust visibility according to account role, referral relationship, and risk.

Unless the referred user actively asks the Referral Member to assist with follow-up, specific service performance requires it, or law requires otherwise, the Platform does not show full contact details, product or order details, suppliers, delivery addresses, payment accounts, customs materials, or information unrelated to rewards to Referral Members. When a user registers through a referral entry point, the Platform will inform the user of the referral relationship and status display arrangement. If applicable law requires separate consent, the user's relevant status will be shown to the Referral Member only after consent is obtained.

Referral Members should use official links, QR codes, or referral codes and invite users to register themselves. If a Referral Member submits another person's name, phone, email, or other information to the Platform, the member must ensure authorization, complete necessary notice, and submit only what is needed for the Program.

The Platform may require Referral Members to explain information sources and may refuse to receive, de-identify, restrict access to, stop using, or delete information that is excessive, incorrect, from an unknown source, or high risk. Referral Members may not use information opened by the Platform for marketing, resale, harassment, public disclosure, or external diversion outside the Program.

Anti-Cheating, Review, and Automated Tools

The Platform may use system rules, account and device associations, network information, click and registration patterns, order and refund status, customer confirmations, complaints, and other reasonable information to identify self-referrals, duplicate accounts, abnormal traffic, false orders, link hijacking, and other violations.

To verify abnormalities, the Platform may conduct manual or system review, and may delay reward confirmation, suspend settlement, or restrict referral entry points or account functions as necessary. To prevent circumvention of risk controls, the Platform may be unable to disclose complete algorithms, thresholds, or third-party confidential information.

If the Platform makes a decision solely through automated processing that legally has a significant impact on an individual, and applicable law requires a channel for explanation, expression of views, or human review, the Platform will handle it as required. Ordinary ranking, prompts, preliminary risk flags, or reviews involving human participation do not automatically fall within that category.

Entrusted Processing, Sharing, and Cross-Border Transfer

To operate the Program, the Platform may provide relevant information within the necessary scope to HubBuyer affiliates and organizations providing identity or business review, banking and payment, tax and accounting, cloud services, communications, analytics, security and risk control, customer service, and professional advisory services. It may also disclose information to corresponding recipients based on user instructions, business transfer, or legal requirements. The Platform will provide and update a list of major third-party recipients on the privacy page, stating recipient names or categories, contact details, and processing purposes. If separate consent is required by law, it will be obtained in the relevant scenario.

Specific recipients may change by country, settlement method, and technical arrangement. The Platform reasonably limits the scope based on purpose, recipient role, and information sensitivity, and where applicable requires service providers to handle information properly through contracts, permissions, or other measures. Third parties that independently determine purposes and means are responsible under their own rules.

Program-related data may be processed in China and other countries or regions where Referral Members, referred users, banks, payment providers, or technical service providers are located. The Platform will adopt safeguards according to the main privacy policy and laws binding the relevant activities. If specific notice, consent, contract, assessment, filing, or other procedures are legally required, they will be completed in the relevant scenario. For transfers of EU personal data to third countries, the Platform will use lawful mechanisms such as Standard Contractual Clauses (SCCs). For provision of personal information from China to overseas recipients, the Platform will complete personal information export standard contract filing, security assessment, protection certification, or other legally required procedures.

The Platform does not sell personal information in the Program for monetary consideration. If an attribution, advertising, or analytics technology is legally defined in a specific region as a "sale" or "sharing" of personal information, the Platform will provide the required notice or choices where applicable.

Retention and Information Security

The Platform retains relevant information during the referral account and cooperation relationship, and for the periods necessary to handle rewards, withdrawals, refunds, chargebacks, taxes, audits, complaints, disputes, and anti-cheating risk control. In determining periods, it considers program and transaction cycles, statutory tax and finance requirements, limitation periods, information sensitivity, and security risks. Logs related to attribution and rewards are retained for no less than the relevant objection period and applicable limitation period. Referral Members may query and export records related to their promotion through the dashboard.

When the retention purpose is achieved and there is no legal basis for continued retention, the Platform will delete, anonymize, or otherwise handle information as permitted by applicable law. Account closure or referral relationship change does not automatically require deletion of records needed for unsettled or settled rewards, refunds, taxes, audits, disputes, and anti-cheating.

The Platform adopts reasonable technical and organizational measures under the HubBuyer Global Privacy Policy according to the nature of information, business scale, and risks. No Internet transmission or storage method can be guaranteed absolutely secure. Referral Members should also properly protect accounts, verification codes, referral entry points, and payee information.

If a personal information security incident occurs or may occur, the Platform will take reasonable remedial measures and assess the impact. Where applicable law requires notification to authorities or affected persons, it will proceed according to law.

Your Rights and Referral Relationship Requests

Referral Members and referred users may, through the official privacy channels listed in the HubBuyer Global Privacy Policy, request inquiry, access, copy, correction, deletion, or exercise other applicable rights according to law. Before processing, the Platform may verify identity, business authorization, account, order, and request scope.

The Platform will handle verifiable and reasonable requests within the period required by applicable law. In general, the Platform will respond within 15 business days after identity verification. Where the GDPR applies, the period will not exceed one month, though complex cases may be extended as permitted by law with notice.

Requests that cannot be verified, are manifestly repetitive or excessive, affect others' rights or trade secrets, or conflict with unsettled rewards or legal retention duties may be restricted or refused to the extent permitted by law.

Referred users may request verification or correction of the referral relationship. The Platform will handle the request based on system records, pending or settled rewards, refunds, disputes, cheating risk, and legal retention duties. Unless information is truly incorrect or law requires otherwise, the request does not automatically retroactively change completed lawful settlements. You also have the right to complain or report to the local personal information protection authority according to law. Where the GDPR applies, you may complain to the data protection authority in your member state.

Minors, Policy Updates, and Contact

Huaban Member promotion and reward settlement services are not intended for minors under 18. Referral Members may not target minors for promotional cooperation or unnecessarily submit minors' information to the Platform. If inappropriate information is found, the Platform will handle it according to actual circumstances and applicable law.

The Platform may update this Policy due to changes in program functions, attribution technology, settlement methods, service providers, or law. The updated Policy applies from the date stated on the page. If an update materially and adversely affects personal rights or applicable law requires separate notice or renewed consent, the Platform will handle it as required.

The operator, contact address, and privacy request channels are those listed in the HubBuyer Global Privacy Policy. To help verification and follow-up, please use the official privacy channels listed in that policy first. Requests received through other channels may be redirected by the Platform.

The Platform may provide English, Japanese, or other language versions. If versions are inconsistent, the Chinese version prevails to the extent permitted by applicable law.