Last updated: 25 May 2026
1. Who we are
This Privacy Policy explains how CML Trading Group (the "Company", "we", "us") collects, uses and protects your personal data when you use the platform at cmltradinggroup.com (the "Platform").
Data Controller:
CML Trading Group
1102, China-Africa Building, No. J9, Shangcheng Avenue,
Futian Subdistrict, Yiwu City, Zhejiang Province, China
Legal representative: Nabil Azaroual
Email: trade@cmltradinggroup.com
Phone: +86 135 1689 4446
2. Developer disclaimer
The Platform was developed by The Berkshire Company SARL AU as an independent technical contractor. aThe Berkshire Company SARL AU does not operate the Platform, does not have ongoing access to user data, and bears no responsibility for the collection, processing or use of personal data by CML Trading Group. All privacy-related requests must be addressed to CML Trading Group at the contact above.
3. What data we collect
- Account data — name, email, phone, company name, country, role (client / supplier / manager).
- Quotation & order data — product descriptions, quantities, target prices, reference images or PDFs you upload.
- Payment data — proof-of-payment uploads, bank transfer references, payment method (we do not process card data directly).
- Communications — support tickets, emails sent through the Platform, WhatsApp messages you initiate.
- Technical data — IP address, browser type, language preference, session timestamps, audit-log entries.
- OAuth profile data — when you sign in with Google: name, email, profile picture, and a stable identifier from the provider.
4. Why we use it
| Purpose | Legal basis |
|---|---|
| Providing the trade platform, processing quotes & orders | Performance of contract |
| Sending transactional emails (verify, password reset, order updates, invoices) | Contract / legitimate business interest |
| Compliance with Chinese, EU and Moroccan tax, customs and accounting law | Legal obligation |
| Platform security, fraud prevention, audit logs | Legitimate interest |
| Marketing emails | Consent only — and you may opt out at any time |
5. Who we share data with
We share data only with processors strictly necessary to operate the service:
- Hosting: Hetzner Online GmbH (Germany / Finland)
- Email delivery: Sendinblue / Brevo SAS (France)
- OAuth providers: Google LLC, WeChat (Tencent)
- Approved manufacturers and freight forwarders in China, the EU and Morocco, strictly for the purpose of fulfilling your orders
- Tax authorities and auditors when required by law
We do not sell your personal data. Cross-border data transfers (e.g., between China and the EU) are protected by Standard Contractual Clauses or equivalent safeguards under applicable law.
6. How long we keep it
- Account & transactional data: for the duration of your account, plus 10 years after closure for accounting / tax-law obligations.
- Quotation attachments & support tickets: 5 years.
- Activity logs: 24 months (rolling).
- Marketing consent: until you withdraw it.
7. Your rights
Depending on your country of residence, you may have the right to:
- Access the personal data we hold about you
- Request correction or deletion
- Restrict or object to processing
- Receive a copy of your data in a portable format
- Withdraw consent at any time
- Lodge a complaint with your local data-protection authority — including, for EU residents, your national supervisory authority, and for Chinese residents, the Cyberspace Administration of China (CAC)
To exercise any of these rights, email trade@cmltradinggroup.com. We will respond within 30 days.
8. Cookies
The Platform sets a single session cookie required for login functionality. No third-party advertising or tracking cookies are used.
9. Security
We use HTTPS / TLS across the Platform, encrypted passwords (PBKDF2), role-based access control, audit logging, and offline encrypted backups. No system is 100% secure; we contractually require equivalent standards from our processors.
10. Changes
We will notify registered users by email of material changes. Continued use after the effective date constitutes acceptance.
11. Contact
Questions about privacy? Email trade@cmltradinggroup.com.