Privacy Policy
Shenyang TOP New Material Co., Ltd. is committed to protecting the privacy and security of your personal and business data. This policy explains how we collect, use, and safeguard information in our B2B operations.
Overview & Scope
This Privacy Policy ("Policy") applies to Shenyang TOP New Material Co., Ltd. (hereinafter "TOP New Material," "we," "our," or "us"), a company established in 1996 and registered in Shenyang, China, engaged in the research, development, production, and manufacturing of Stellite alloys and cobalt-based alloys.
This Policy governs the collection, processing, storage, and protection of personal and business data obtained through our website, direct business communications, trade inquiries, contractual relationships, and any other interactions with our company. It applies to all individuals who interact with us in a professional capacity, including procurement managers, technical managers, engineers, and representatives of oilfield service companies, equipment OEMs, and energy engineering enterprises worldwide.
We operate primarily in a business-to-business (B2B) context. The data we process typically relates to professional contacts and business transactions rather than consumer relationships. We are committed to handling all data responsibly and in compliance with applicable data protection laws, including but not limited to the Personal Information Protection Law of the People's Republic of China (PIPL), the General Data Protection Regulation (GDPR) where applicable to our European contacts, and other relevant international privacy frameworks.
B2B Context: As a supplier to the global oil and gas industry, the personal data we process is predominantly professional contact information associated with business transactions. We do not engage in consumer marketing or process sensitive personal data beyond what is strictly necessary for legitimate business operations.
Data Controller
Shenyang TOP New Material Co., Ltd. acts as the data controller for personal data processed in connection with our business activities. Our contact details are:
Data We Collect
We collect and process only the data necessary to conduct legitimate business activities and provide our alloy material solutions. The categories of data we may collect include:
Business Contact Information
- Full name and professional title
- Company name and industry sector
- Business email address
- Office phone and fax numbers
- Company mailing and shipping address
Transaction & Commercial Data
- Inquiry and quotation details
- Purchase orders and contract terms
- Product specifications and drawings
- Shipping and logistics records
- Payment and invoicing information
Technical & Application Data
- Equipment and application requirements
- Material performance specifications
- Customization requests and drawings
- Field test and feedback reports
- Quality inspection correspondence
Website & Digital Data
- IP address and browser type
- Pages visited and session duration
- Contact form submissions
- Cookie and analytics data
- Referral source and geographic region
We do not intentionally collect sensitive personal data (such as health, biometric, or financial account data) unless strictly required by a specific transaction and with explicit consent.
How We Use Your Data
We use the data collected solely for the following legitimate business purposes:
Processing Inquiries & Quotations
To respond to requests for product information, technical specifications, pricing, and customized alloy material solutions including Stellite grades, cobalt-based alloys, and hardfacing consumables.
Contract Fulfilment & Order Management
To execute purchase orders, manage production schedules, coordinate logistics, and ensure delivery of alloy products including bars, plates, special-shaped parts, welding wires, and powders.
Technical Support & Customization
To provide material R&D collaboration, customized product design based on client drawings and application requirements, and ongoing technical consultation for downhole and high-temperature applications.
Quality Assurance & Compliance
To maintain quality records in accordance with ISO9001, IATF16949, and other certifications, and to provide material test reports, certificates of conformance, and traceability documentation.
Business Communication & Relationship Management
To maintain ongoing supplier-client relationships, send relevant product updates, industry news, and technical bulletins to existing contacts where there is a legitimate interest or prior consent.
Legal & Regulatory Compliance
To comply with applicable Chinese laws, export control regulations, international trade compliance requirements, and to respond to lawful requests from government authorities.
Website Analytics & Improvement
To understand how visitors use our website, improve user experience, and optimize content for procurement and technical professionals in the oil and gas sector.
We do not sell, rent, or trade personal data to third parties for marketing purposes. We do not use automated decision-making or profiling that produces significant legal effects.
Legal Basis for Processing
We process personal data only when we have a valid legal basis to do so. The applicable legal bases are:
| Processing Activity | Legal Basis |
|---|---|
| Responding to inquiries and quotations | Pre-contractual steps |
| Order fulfilment and contract execution | Contract performance |
| Accounting, invoicing, and tax records | Legal obligation |
| Quality records and certification compliance | Legal obligation |
| Sending technical updates to existing clients | Legitimate interest |
| Marketing communications to new prospects | Consent |
| Website analytics and performance tracking | Legitimate interest / Consent |
Data Sharing & Disclosure
We do not sell or rent your personal data. We may share data only in the following limited circumstances:
Supply Chain & Logistics Partners
Shipping companies, freight forwarders, and customs agents may receive contact and address information strictly necessary to fulfill delivery of alloy products. These parties are bound by confidentiality obligations.
Research & Academic Partners
In the context of collaborative R&D with the Institute of Metal Research (Chinese Academy of Sciences) and Northeastern University, anonymized or aggregated technical data may be shared. No personal contact data is disclosed to academic partners without explicit consent.
Professional Service Providers
IT service providers, cloud hosting operators, CRM system vendors, and financial auditors may process data on our behalf under strict data processing agreements and confidentiality terms.
Legal & Regulatory Authorities
We may disclose data to government agencies, regulators, or law enforcement when required by applicable law, court order, or to protect our legal rights and the safety of our operations.
Business Transfers
In the event of a merger, acquisition, or sale of business assets, personal data may be transferred as part of the transaction. We will notify affected parties and ensure continued protection under equivalent privacy standards.
International Data Transfers
As a global supplier serving the international oil and gas industry, we may transfer personal data across borders in the course of our business operations. Data is primarily processed and stored in China, where our headquarters and production facilities are located.
When transferring data to clients, partners, or service providers outside of China, we apply appropriate safeguards in compliance with the Personal Information Protection Law (PIPL) and other applicable regulations, including:
- Completing security assessment procedures required by Chinese authorities for cross-border data transfers where applicable
- Entering into standard contractual clauses or equivalent data transfer agreements with international recipients
- Limiting transferred data to only what is necessary for the specific business transaction or service
- For clients in the European Economic Area: ensuring GDPR-compliant transfer mechanisms are in place
Data Retention
We retain personal data only for as long as necessary to fulfil the purposes for which it was collected, or as required by applicable laws and regulations. Our retention guidelines are:
| Data Category | Retention Period | Basis |
|---|---|---|
| Pre-sale inquiries (no contract) | 2 years | Legitimate interest |
| Contracts and purchase orders | 10 years | Legal obligation / Contract |
| Financial and invoicing records | 10 years | Chinese accounting law |
| Quality and test records | 15 years | ISO certification requirements |
| Marketing communications | Until opt-out | Consent |
| Website analytics data | 26 months | Legitimate interest |
Upon expiry of the retention period, data is securely deleted or anonymized. Data subject to ongoing legal disputes may be retained until the matter is resolved.
Security Measures
We apply the same rigorous quality standards to data security that we apply to our alloy manufacturing processes. We implement a comprehensive set of technical and organizational measures to protect your data against unauthorized access, disclosure, alteration, or destruction.
Encryption
Data in transit is encrypted using TLS 1.2+. Sensitive stored data is encrypted at rest using industry-standard algorithms.
Access Controls
Role-based access control limits data access to authorized personnel on a need-to-know basis. Multi-factor authentication is enforced for system access.
Monitoring & Audit
Security monitoring, intrusion detection, and regular security audits are conducted to identify and address vulnerabilities proactively.
Staff Training
All personnel handling personal data receive regular privacy and security training. Confidentiality obligations are embedded in employment contracts.
Secure Data Storage
Business data is stored on secure servers with regular backups, physical security controls, and disaster recovery procedures.
Breach Response
We maintain an incident response plan. In the event of a data breach, we will notify affected parties and relevant authorities within legally required timeframes.
While we implement robust security measures, no system is completely immune to security risks. We encourage you to use secure communication channels when sharing sensitive business or technical information with us.
Your Rights
Depending on your jurisdiction and applicable data protection laws, you may have the following rights regarding your personal data. We are committed to honoring these rights in a timely and transparent manner.
Right of Access
Request confirmation of whether we process your personal data and obtain a copy of the data we hold about you.
Right to Rectification
Request correction of inaccurate or incomplete personal data. We encourage you to keep your business contact information up to date.
Right to Erasure
Request deletion of your personal data where it is no longer necessary for the original purpose, subject to legal retention obligations.
Right to Restriction
Request that we restrict processing of your data in certain circumstances, such as while accuracy is being contested.
Right to Data Portability
Request a structured, machine-readable copy of data you have provided to us, where technically feasible.
Right to Object
Object to processing based on legitimate interests, including direct marketing communications. We will cease processing upon a valid objection.
Right to Withdraw Consent
Where processing is based on consent, you may withdraw it at any time without affecting the lawfulness of prior processing.
Right to Lodge a Complaint
You have the right to lodge a complaint with the competent data protection authority in your jurisdiction if you believe your rights have been violated.
How to Exercise Your Rights
To exercise any of the above rights, please submit a written request to privacy@topnewmaterial.com with the subject line "Data Subject Request." We will acknowledge your request within 5 business days and respond within 30 days. We may need to verify your identity before processing your request.
Cookies & Tracking Technologies
Our website uses cookies and similar tracking technologies to improve functionality, analyze website traffic, and enhance user experience for procurement and technical professionals visiting our site.
Strictly Necessary Cookies: Required for the website to function. These cannot be disabled and do not require consent. Examples include session management and security tokens.
Analytics Cookies: Help us understand how visitors navigate our site, which pages are most visited, and how long users spend reviewing product and capability information. Activated only with consent.
Functional Cookies: Remember your preferences such as language selection and region. These improve your browsing experience but are not strictly necessary.
You may control cookie settings through your browser preferences or our cookie consent tool. Disabling certain cookies may affect website functionality. We do not use advertising or cross-site tracking cookies.
Children's Privacy
Our website, products, and services are directed exclusively at business professionals in the oil and gas industry and related sectors. We do not knowingly collect, process, or store personal data from individuals under the age of 18.
If we become aware that personal data of a minor has been inadvertently collected, we will take immediate steps to delete such data. If you believe a minor has provided personal data to us, please contact us at privacy@topnewmaterial.com.
Changes to This Policy
We may update this Privacy Policy periodically to reflect changes in our business practices, applicable laws, or data protection standards. When we make material changes, we will:
- Update the "Last Updated" date at the top of this Policy
- Notify existing clients and contacts via email where material changes affect their rights or our processing activities
- Post a prominent notice on our website for a period of at least 30 days following significant updates
We encourage you to review this Policy periodically. Continued use of our website or engagement with our services after the effective date of any changes constitutes acceptance of the updated Policy.
Contact Us
If you have any questions, concerns, or requests regarding this Privacy Policy or our data processing practices, please contact us through any of the following channels. We are committed to responding promptly and transparently.
Registered Office
Shenyang, Liaoning
Province, China
Response Commitment
We acknowledge all privacy-related inquiries within 5 business days and aim to provide a full response within 30 calendar days. Complex requests may require additional time, in which case we will notify you of the expected timeline.
© 2024 Shenyang TOP New Material Co., Ltd. All rights reserved.
This Privacy Policy is governed by the laws of the People's Republic of China.