Privacy Policy

Introduction and Who We Are

This Privacy Policy describes the practices of the digital and counter operations published under the name ClearNature on behalf of DingZhou QingRan Trading Co., Ltd. The developer name ClearNature identifies the team that maintains this website and its routing tools, while the trading operations described below are carried on by DingZhou QingRan Trading Co., Ltd. from its counting house at 100m West of Xinhua Middle School, Nancheng District, Baoding City - 073000, China (CN). Throughout this policy the terms we, us and our refer to DingZhou QingRan Trading Co., Ltd. together with ClearNature where the context involves the website, and you refers to any visitor, client or correspondent who interacts with our counter.

We believe that trust in trade begins with trust in the handling of information. A route can only be weighed honestly if the people who supply the facts feel safe doing so. This policy therefore sets out, in plain language, what we collect, why we collect it, how long we keep it, who may see it, and what you can ask us to do about it. We have written it to be read rather than to be skimmed, and we have avoided legal fog wherever a clear sentence will do the work.

This policy applies to our website, to messages sent to our counter, to routing notes and brokerage slips created for clients, and to any related correspondence. It does not apply to third party websites that we may link to, and it does not cover information that we receive in a purely personal or household capacity. Where a separate agreement exists between you and DingZhou QingRan Trading Co., Ltd., that agreement may set additional terms, and nothing here reduces the protections that the law guarantees to you.

The Data Controller and Contact Details

The controller responsible for personal information processed through this website and through the Baoding counting house is DingZhou QingRan Trading Co., Ltd. Our registered and operating address is set out below, and our counter answers correspondence from the same location.

If you have any question about this policy, about the information we hold, or about the way a particular message was handled, please write to routing@brug-trade.com and mark the message as a privacy enquiry so that it reaches the right member of the bench. We treat privacy enquiries as a priority and we aim to reply within one working day, and in every case within the periods described later in this policy.

Scope of This Policy

This policy covers the personal information we process when you visit our website, when you send a message through the contact form or by email, when you telephone the counter, when we open a routing note or brokerage slip for you, when we issue a market letter to you, when we conduct a cargo review round or a counter sitting with you, and when you interact with us in any other ordinary business way. It applies whether those interactions happen in person, by telephone, by email or through any digital channel we operate.

Some parts of our work involve information about companies rather than individuals. Where a company record contains the name or contact details of a person, we treat that element as personal information and protect it under this policy. This policy does not cover information that has been fully anonymised so that it can no longer be linked to any individual, because such information is not personal information at all.

Information We Collect

We collect only the information that is needed to route a consignment, to answer a question, to issue a letter or to maintain the record that trade requires. We do not collect information simply because it might one day be useful, and we do not ask for more than the task in front of us demands. The categories below describe what is normally involved.

Information you give us

When you contact us, you may give us your name, your email address, a telephone number, the name of your organisation, your role, and the content of your message. When we open a routing note or a brokerage slip for you, we may record the origin and destination of a consignment, the nature and weight of the cargo, the target dates, the parties involved and any special instructions you have named. When you attend a counter sitting, we may record the decisions made and the people present so that the record is complete.

Information collected automatically

When you visit our website, our hosting environment may record technical information such as the type of browser you use, the pages you open, the time of your visit and the address from which the request was made. This information is used to keep the site working reliably and to understand which parts of it are useful. We do not use it to build a personal profile of you, and we do not combine it with information from unrelated sources.

Information from third parties

We may receive information about you from a colleague, from a forwarding partner, from a carrier or from another party on a route where you are named as a contact. In such cases we use the information only for the purpose for which it was shared, and we ask the party who shared it to confirm that they were entitled to do so.

How We Use Personal Information

We use personal information to perform the work you have asked us to perform. That includes opening and maintaining routing notes and brokerage slips, securing booking windows, issuing market letters, running cargo review rounds, arranging counter sittings, answering questions and keeping the records that a trading house is expected to keep. We also use information to protect the security of our systems, to detect misuse, and to meet the obligations that the law places on a business of our kind.

We do not sell personal information. We do not rent it, trade it or exchange it for advertising. We do not use the content of your messages to train any model, and we do not share the details of your routes with other clients. If we ever wish to use information for a purpose that is genuinely new, we will tell you first and, where the law requires it, ask for your agreement before proceeding.

Our Lawful Basis for Processing

Where the law requires us to identify a basis for processing, we rely on one or more of the following. We rely on the performance of a contract, or steps taken at your request before a contract is formed, when we open a routing note, secure a booking window or run a cargo review round. We rely on our legitimate interests when we keep ordinary business records, protect our systems and answer correspondence in a way that a client would reasonably expect. We rely on consent for any optional communication that you have specifically agreed to receive. We rely on a legal obligation when we are required to keep or disclose information under applicable law.

Where we rely on consent, you may withdraw it at any time by writing to the counter, and the withdrawal will not affect the lawfulness of any processing carried out before the withdrawal. Where we rely on legitimate interests, we have considered the effect on you and we believe our interests do not override your rights and freedoms.

When We Share Personal Information

Trade cannot happen in isolation, so some sharing is unavoidable. We share personal information with forwarding partners, carriers and agents only to the extent needed to move your consignment or to answer your enquiry. We share it with service providers who host our website, deliver our email or maintain our systems, and we require those providers to protect the information and to use it only for the service they provide to us. We share it with professional advisers when necessary, and with public authorities when the law requires it.

Whenever we share information, we share the minimum that the task requires. We do not provide contact lists to other clients, we do not disclose the terms of one client to another, and we do not permit any partner to use our information for its own marketing. If a partner needs to process information outside the scope of the task, that partner must come to us first, and we will consider the request against this policy.

International Transfers

Our counting house is in Baoding, China, and some of our service providers or trading partners may be located in other countries. Information may therefore be transferred to, stored in or accessed from a country that has different privacy laws from the one in which you live. Where such a transfer happens, we take reasonable steps to ensure that the information continues to receive a level of protection consistent with this policy and with applicable law.

Those steps may include contractual commitments from the recipient, a review of the legal environment of the destination, and internal measures that limit who may access the information. If you would like to know more about the safeguards that apply to a particular transfer, write to the counter and we will explain the arrangement that covers your information.

How Long We Keep Information

We keep personal information for as long as it is needed for the purpose for which it was collected, and for the period that ordinary business practice and applicable law require. Routing notes, brokerage slips and related records are typically kept for a period that allows us to answer questions about a consignment long after it has moved, because trade disputes are often raised months or years later. Correspondence is kept for a comparable period so that the record of what was agreed remains available.

When information is no longer needed, we delete it or anonymise it. We review our records on a regular cycle so that information does not linger simply because nobody remembered to remove it. Where we are required by law to keep a record for a fixed period, we keep it for that period and then remove it. If you ask us to delete information and we are not required to keep it, we will do so within the period described later in this policy.

How We Protect Information

We protect information with a combination of technical measures and simple human discipline. Access to our systems is limited to the members of the bench who need it for their work, and each member is accountable by name in the record. We use access controls, encryption where appropriate, routine backups and monitoring to detect unusual activity. We train our team on safe handling, and we review our measures when the nature of our work or the technology we use changes.

No system can guarantee absolute security, and we do not pretend otherwise. What we promise is that we take the risk seriously, that we act quickly if a problem occurs, and that we will tell you without delay if a breach is likely to affect your rights. We keep a written procedure for responding to incidents, and we involve independent advice where the circumstances call for it.

Cookies and Similar Technologies

Our website uses a small number of cookies and similar technologies to keep the site working and to understand basic usage. These include essential cookies that allow the navigation to function, and, where applicable, measurement cookies that help us see which pages are visited most often. We keep this list short on purpose, and we do not use advertising cookies.

You can control cookies through the settings of your browser. Removing or blocking essential cookies may affect how the site behaves, but it will not prevent you from writing to the counter by email or by telephone. Where the law requires us to obtain your agreement before placing a non-essential cookie, we will ask for that agreement and we will respect your choice.

Your Rights

Depending on where you live, you may have a number of rights over the personal information we hold about you. These commonly include the right to be told what we hold, the right to receive a copy, the right to correct inaccuracies, the right to ask us to delete information in certain circumstances, the right to restrict how we use it, the right to object to certain processing, and the right to withdraw consent where consent is the basis for processing.

You also have the right to complain to a supervisory authority if you believe we have handled your information improperly. We would rather you came to us first, so that we can try to put the matter right, but this does not limit your right to approach an authority directly. To exercise any right, write to routing@brug-trade.com with enough detail for us to identify the information at issue, and we will explain the steps involved.

How to Exercise Your Rights

Write to the counter at routing@brug-trade.com and describe what you would like us to do. We may ask you to confirm your identity so that we do not disclose information to the wrong person, but we will ask only for what is reasonably needed. We will respond within the period required by applicable law, and in any event within thirty days unless the request is unusually complex, in which case we will tell you why more time is needed.

If we cannot comply with a request, we will explain the reason in writing. Where a request is manifestly unfounded or excessive, we may refuse it or charge a reasonable fee that reflects the administrative cost, and we will set out that decision clearly so that you can challenge it if you disagree.

Privacy for Children

Our services are intended for businesses and for adults acting in a professional capacity. We do not knowingly collect personal information from children. If you believe that a child has provided information to us, please write to the counter and we will investigate and, where appropriate, delete the information promptly.

Where a young person writes to us in the ordinary course of a family business, we handle the information with the same care described in this policy, and we will not use it for any purpose that is unrelated to the enquiry that brought it to us.

Marketing and Optional Communication

The market letters described in our services pages are a working communication that supports an active routing arrangement, and they are not promotional messages. We do not send general marketing email to people who have not asked for it. If you would like to receive additional communication from us, you may ask, and you may withdraw that request at any time by writing to the counter or by using the unsubscribe method offered in the message itself.

Even where you withdraw from optional communication, we may still contact you about an active consignment, a booking window that is in force or a legal obligation that concerns you, because such contact is part of the service you have asked us to provide.

Links to Other Websites

Our website may contain links to websites that we do not control. A link does not mean that we endorse the practices of the destination or that we are responsible for them. When you follow a link, you leave the protection of this policy and enter a site with its own rules. We recommend that you read the privacy information offered by any site you visit, especially before you provide personal information to it.

If you reach our site from another site, the operator of that site may have collected information about you before you arrived. We cannot control that collection and we do not receive the information it produces unless you give it to us yourself.

Automated Decisions and Profiling

We do not make decisions that have a significant effect on you solely by automated means. Route recommendations are prepared by members of the bench, and while we use well chosen tools to organise the information behind those recommendations, a person reviews the result before it is sent to you. If in future we introduce an automated element that could materially affect a client, we will describe it clearly and provide a way to ask for human review.

We do not build profiles of visitors for advertising, we do not sell profiles to data brokers, and we do not use information about a client to infer sensitive characteristics.

Changes to This Policy

We review this policy from time to time so that it continues to reflect the way we work and the law that applies to us. When we make a material change, we will update the effective date at the top of the page and, where the change affects you significantly, we will take reasonable steps to bring it to your attention. We encourage you to return to this page occasionally so that you know how we handle information at any given time.

If you continue to use our website or to correspond with the counter after a change has taken effect, we will treat that as acceptance of the updated policy to the extent that such acceptance is permitted by law. Where your agreement is legally required for a particular change, we will ask for it separately and we will not apply the change until we have received it.

Complaints and Dispute Resolution

If you are unhappy with the way we have handled your information, please tell us first. Write to routing@brug-trade.com, describe the matter, and give us the opportunity to respond. We will investigate promptly, we will explain our findings, and where we have made a mistake we will correct it. Many concerns can be settled quickly once the record is in front of both of us.

If you remain dissatisfied, you may raise the matter with the supervisory authority in the place where you live or work, or with the authority in the jurisdiction where we operate, as the applicable law allows. We will cooperate fully with any such authority and we will not penalise you for exercising this right.

Contacting Us About Privacy

For any privacy question, request or complaint, please use the contact details below. The developer name ClearNature maintains the website on behalf of the trading house, and messages about the website itself may also be directed to the same counter address.

We aim to acknowledge every privacy message within one working day and to resolve it within the periods described earlier in this policy. If a matter is complex, we will tell you what we are doing and when you can expect a further update, rather than leaving you to wonder.

Governing Terms and Final Notes

This policy should be read together with our Terms of Service, which describe the terms on which we provide our routing and brokerage services. Where a conflict arises between this policy and the Terms of Service on a matter of privacy, this policy prevails for the processing of personal information. The headings used in this policy are for convenience only and do not affect the meaning of the text.

Nothing in this policy limits any right that applicable law grants to you, and nothing in this policy creates a right that the law does not already provide. If any part of the policy is found to be unenforceable, the remaining parts continue in force. We thank you for taking the time to read it, and we look forward to serving you with the same honesty that this policy describes.