01Scope of this policy

This Privacy Policy explains how FirstBridge Digital handles personal information when you visit our website at www.firstbridgedigital.com (the “Website”), contact us, engage our services, attend an event, subscribe to our communications or apply to work with us. It also explains how we handle personal information in the course of providing our digital marketing and related services. Our Terms of Use govern your use of the Website.

“Personal information” or “personal data” means information that identifies, relates to, describes or can reasonably be linked to an individual. It does not include information that has been aggregated or de-identified so that it can no longer be linked to an individual.

When we act for a client

Sometimes we process personal information on behalf of a client — for example, when managing a client’s advertising account, influencer campaign or customer database. In those cases, we act as a processor or service provider under the client’s instructions and the applicable data processing agreement. The client is responsible for the relevant privacy notice. If you are an individual whose information is held in a client’s campaign or database, please contact that client first; we will help them respond as required.

What this policy does not cover

This policy does not apply to third-party websites, platforms or services that we do not control, even if we link to them or work with them. Their own privacy notices apply.

02Who we are

FirstBridge Digital (“FirstBridge”, “we”, “us” or “our”) is the brand name used by Hangzhou Lingjuli Chuhai Digital Technology Co., Ltd. (杭州零距离出海数字科技有限公司), registered in Hangzhou, Zhejiang, China, at Room 2903, Building A, No. 4760 Jiangnan Avenue, Puyan Street, Binjiang District, Hangzhou, Zhejiang, China.

For the purposes of the EU/UK General Data Protection Regulation and similar laws, we are the data controller of the personal information described in this policy, except where we process it on behalf of a client as a processor. For the purposes of the California Consumer Privacy Act, as amended (“CCPA”), we act as a “business” for that information.

You can contact us about privacy at [email protected] or by post at the address above. Please include “Privacy” in the subject line so that your message reaches the right team.

03Information we collect

The information we collect depends on how you interact with us. The main categories are:

Sensitive information

We do not intentionally request sensitive personal information — such as health data, biometric identifiers, precise geolocation, religious beliefs, or government identification numbers — through the Website. Please do not submit this kind of information through public forms unless we have specifically asked for it and explained how it will be protected. If you provide information about another person, you must have the authority and any required consent to do so.

04How we collect it

• Directly from you. When you fill in a form, email or call us, request a proposal, subscribe to updates, attend an event, participate in a survey or apply for a role.
• Automatically. When you use the Website, we and our service providers may collect technical and usage information through cookies, pixels, server logs and similar technologies, subject to your choices.
• From clients and partners. When a client or business partner shares contact or project information with us as part of an engagement, or when a colleague introduces you.
• From public and commercial sources. We may supplement business contact details with information from public sources, professional networks or permitted data providers, where the law allows.
• From service providers. For example, analytics providers, advertising platforms, payment processors and event organisers may provide us with information about your interactions.

05How and why we use it

We use personal information only for the purposes for which we collected it, compatible purposes, or as required or permitted by law. The table below summarises our main purposes and the legal bases we rely on under the EU/UK GDPR. Under other laws, such as China’s Personal Information Protection Law (“PIPL”), we rely on the corresponding bases, including consent, performance of a contract, legal obligations and other permitted grounds.

Where we rely on legitimate interests, we balance our interests against your rights and expectations. You can object to that processing as described in section 11. Where we rely on consent, you can withdraw it at any time, without affecting the lawfulness of processing carried out before withdrawal.

We do not use personal information for automated decisions that produce legal effects or similarly significant effects concerning you. We may use aggregated or de-identified information for analytics, reporting and service development.

06Cookies and tracking

Cookies are small text files placed on your device. We also use pixels, tags, local storage and similar technologies (together, “cookies”) to operate the Website, understand how it is used and, where permitted, measure and improve our marketing.

Depending on which features are enabled and which pages you visit, third-party providers such as analytics and advertising platforms may set cookies through the Website. Those providers process information under their own privacy policies. We do not control their cookies, but we require appropriate contractual protections where we engage them.

Where required by law, we ask for your consent before setting non-essential cookies, and you can change or withdraw your choices at any time through the cookie banner or settings made available on the Website. You can also block or delete cookies through your browser or device settings; blocking some cookies may affect Website functionality. We honour Global Privacy Control signals where required by applicable law.

07How we share information

We do not sell personal information for money. We share it only as described below, and only to the extent necessary for the relevant purpose.

• Service providers. Companies that help us operate our business and the Website, such as hosting and cloud providers, email and CRM platforms, analytics providers, advertising and media partners, payment processors, IT support and security providers. They may access personal information only to provide services to us and are bound by confidentiality and data-protection obligations.
• Clients and project partners. When we deliver services, we may share project information, including contact details for creators, vendors or client personnel, with the client and other partners involved in the engagement, as necessary for the project.
• Affiliates. Our group companies and affiliates, for the purposes described in this policy and subject to appropriate protections.
• Professional advisers. Lawyers, accountants, auditors, insurers and other advisers, where necessary and subject to professional confidentiality obligations.
• Authorities and legal processes. Courts, regulators, law enforcement or other authorities when we believe disclosure is required by law, necessary to protect rights or safety, or relevant to a legal claim.
• Business transfers. A buyer, investor or successor in connection with a merger, acquisition, financing, reorganisation or sale of all or part of our business, subject to appropriate confidentiality protections.
• With your consent. Any other recipient you authorise us to share with.

Some privacy laws define “sale” or “sharing” broadly to include disclosing personal information for cross-context behavioural advertising. If we engage in those activities, we do so only where permitted, with any consent required by law, and you can opt out by emailing [email protected] with the subject “Do Not Sell or Share My Personal Information”.

08International transfers

We are headquartered in China, and the service providers and partners we use may be located in other countries, including the United States, the European Economic Area, the United Kingdom, Singapore and other jurisdictions where we or they operate. As a result, your personal information may be transferred to, stored in or accessed from countries whose data-protection laws differ from those in your country.

Where required, we use appropriate safeguards for these transfers, such as standard contractual clauses approved by the European Commission, the UK International Data Transfer Addendum, contractual confidentiality and security commitments, and, where applicable under PIPL, a security assessment, standard contract filing or separate consent. We also take steps to ensure that transferred information receives an adequate level of protection.

You can contact us for more information about the safeguards we use for a particular transfer.

09How long we keep it

We keep personal information only for as long as necessary for the purposes described in this policy, including to meet legal, tax, accounting and reporting requirements, resolve disputes and enforce our agreements. Our usual retention periods are:

• Inquiries and prospective clients: up to 24 months after our last meaningful contact, unless we agree to keep in touch for longer.
• Client and project records: for the duration of the engagement and up to 7 years afterwards, to meet contractual, tax, accounting and legal requirements.
• Billing and tax records: for the period required by applicable law, which is generally 7 to 10 years.
• Marketing contacts: until you opt out, plus a suppression record so that we do not contact you again by mistake.
• Website analytics: typically up to 14 months, depending on the tool and configuration.
• Recruitment records: up to 24 months after the application process ends, unless you agree to a longer period or we are required to keep them.
• Cookies: for the period stated in the cookie settings, ranging from the duration of your session to up to 24 months.

When information is no longer needed, we delete it, anonymise it or securely aggregate it. If we cannot delete it immediately — for example, because it is in a backup archive — we isolate it and protect it until deletion is possible. We may also retain information for longer where required by law or for the establishment, exercise or defence of legal claims.

10How we protect it

We use administrative, technical and organisational measures designed to protect personal information against unauthorised access, loss, misuse, alteration or destruction. These measures include access controls based on least privilege, encrypted connections where appropriate, secure configuration, vendor due diligence, confidentiality commitments and regular review of our practices.

No method of transmission over the internet or method of electronic storage is completely secure, and we cannot guarantee absolute security. You are responsible for keeping your own devices and account credentials secure. If you have reason to believe that your interaction with us is no longer secure, please contact us immediately at [email protected].

If we become aware of a personal data breach that requires notification under applicable law, we will notify the relevant authorities and affected individuals as required.

11Your rights and choices

Depending on where you live and the law that applies, you may have some or all of the following rights:

• Access. Ask whether we hold personal information about you and request a copy.
• Correction. Ask us to correct inaccurate or incomplete information.
• Deletion. Ask us to delete personal information, subject to legal exceptions.
• Restriction and objection. Ask us to restrict certain processing, or object to processing based on legitimate interests or direct marketing.
• Portability. Request a portable copy of information you provided to us, where the law provides this right.
• Withdraw consent. Withdraw any consent you have given at any time, without affecting processing that took place before withdrawal.
• Opt out of marketing. Stop receiving marketing communications, as described in section 12.
• Opt out of sale or sharing. Ask us not to sell or share your personal information for cross-context behavioural advertising, where those concepts apply.
• Non-discrimination. Exercise your privacy rights without being denied services or receiving a different level of service, where the law prohibits such discrimination.
• Authorised agent. Use an authorised agent to submit a request on your behalf, subject to verification of your identity and their authority.
• Appeal. Appeal our decision on a privacy request where the law gives you that right.

How to make a request

Email [email protected] with the subject “Privacy Request”. Tell us what you want us to do and which country or state you are contacting us from. We may need to verify your identity before acting on a request, and we may ask for additional information to help us locate your records. We will respond within the period required by applicable law. We do not normally charge a fee, but we may charge a reasonable fee or refuse a request if it is manifestly unfounded, excessive or repetitive, where the law allows.

California residents

If you are a California resident, you may have the right to know the categories and specific pieces of personal information we have collected, the sources, purposes and categories of third parties to whom we disclose it, and to request deletion, correction or portability, subject to legal exceptions. You also have the right to opt out of the sale or sharing of personal information and to limit the use of sensitive personal information, where applicable. We do not knowingly sell or share the personal information of consumers under 16. We will not discriminate against you for exercising your rights. To opt out of sale or sharing, email us with the subject “Do Not Sell or Share My Personal Information”.

EEA and UK residents

You may also lodge a complaint with your local data-protection supervisory authority. We encourage you to contact us first so that we can try to resolve your concern. If you are in the EEA or UK and we are required to appoint a representative, their details will be made available on request and published here when appointed.

China

Under PIPL and related laws, you may have rights to know, decide, access, copy, correct, supplement, delete, withdraw consent, request an explanation and complain. You may also contact the relevant cyberspace administration, market regulation or public security authorities. Where we process your information based on consent, you can withdraw it at any time.

12Marketing communications

We may send you business updates, insights, event invitations and information about our services where we have a lawful basis to do so. You can opt out at any time by using the unsubscribe link in our emails or by emailing [email protected]. We will process your request promptly and keep a suppression record so that we do not contact you again by mistake.

We may still send you service-related messages that are necessary for an engagement, such as project updates, invoices, security notices or responses to your requests. These are not marketing communications.

We do not share your email address with third parties for their own marketing without your consent.

13Children

The Website and our Services are intended for businesses and professional audiences, not for children. We do not knowingly collect personal information from children under 16 (or the minimum age required by local law). If you are under that age, please do not use the Website or submit personal information to us. If we learn that we have collected personal information from a child without appropriate consent, we will take reasonable steps to delete it. If you believe a child has provided us with personal information, please contact us at [email protected].

14Third-party links

The Website may link to third-party websites, platforms or resources. We do not control those third parties and are not responsible for their content, security or privacy practices. This policy does not apply to them. We encourage you to read the privacy notice of every website or service you use.

15Changes to this policy

We may update this Privacy Policy from time to time to reflect changes in our practices, the Website, our Services or applicable law. We will post the revised policy on this page and update the “Last updated” date. If the changes are material, we will take reasonable steps to notify you — for example, by posting a prominent notice on the Website or contacting you directly where we have your details. Your continued use of the Website after the effective date means you acknowledge the revised policy.

16Complaints

If you are not satisfied with our response, you can complain to your local data-protection authority. In the EEA or UK, this is the supervisory authority in the country where you live, work or where the alleged infringement occurred. In California, you may contact the California Attorney General. In China, you may contact the relevant cyberspace administration, market regulation or public security authority. We appreciate the chance to address your concern first.

You can also write to us at the postal address below. Please mark the envelope “Privacy”.