Privacy Policy

1. Who We Are

Topwisdom Consulting Co., Ltd.
Address: Zhejiang, China
Email: info@complydpp.cloud
Phone: +86 188 6762 9113

ComplyMatrix is a Digital Product Passport compliance platform operated by Topwisdom Consulting Co., Ltd. This Privacy Policy explains how we collect, use, store and protect your personal data when you use our platform.

2. Data We Collect

We collect the following categories of personal data:

• Account data: name, email address, company name, phone number
• Usage data: DPP records created, login history, audit logs
• Communication data: messages sent via our contact form
• Technical data: IP address, browser type, device information

3. Legal Basis for Processing

We process your personal data based on the following legal grounds under Article 6 of the GDPR:

• Contract performance: To provide our DPP platform services to you
• Legitimate interests: To improve our platform, ensure security, and prevent fraud
• Consent: Where you have explicitly agreed to receive marketing communications
• Legal obligation: To comply with applicable EU regulations

4. How We Use Your Data

• To create and manage your account and organization
• To enable you to create and manage Digital Product Passports
• To send transactional emails (invitations, notifications)
• To provide customer support
• To comply with legal and regulatory obligations

5. Data Retention

We retain your personal data for as long as your account is active. After account deletion, we retain your data for a period of 2 years to comply with legal obligations, resolve disputes, and enforce our agreements. After this period, your data is permanently deleted.

DPP records are retained in accordance with applicable EU regulations, which may require retention for up to 10 years after the last product is placed on the market.

6. Third-Party Service Providers

We use the following third-party services to operate our platform:

Each third-party provider has been carefully selected and contractually obligated to process your data in compliance with the GDPR. Data processed by Tencent Cloud is stored on servers located in Frankfurt, Germany (EU).

7. Data Subject Rights

Under the GDPR, you have the following rights:

• Right to access — Request a copy of your personal data
• Right to rectification — Correct inaccurate data
• Right to erasure — Request deletion of your data (“right to be forgotten”)
• Right to restrict processing — Limit how we use your data
• Right to data portability — Receive your data in a structured format
• Right to object — Object to processing based on legitimate interests

To exercise any of these rights, contact us at info@complydpp.cloud. We will respond within 30 days.

8. Data Security

We implement appropriate technical and organisational measures to protect your personal data, including:

• Encryption in transit (HTTPS/TLS)
• Encrypted password storage (bcrypt)
• Role-based access control
• Regular security audits
• EU-based server infrastructure (Frankfurt, Germany)

9. International Data Transfers

Your data is primarily stored on servers in Frankfurt, Germany (EU). Where third-party services are used (such as Gmail for email), appropriate safeguards are in place, including Standard Contractual Clauses (SCCs) adopted by the European Commission.

10. Contact Us

If you have any questions about this Privacy Policy, please contact us:
Email: info@complydpp.cloud
Phone: +86 188 6762 9113