1. General Overview & Data Controller The protection of your privacy is of the utmost importance to EuroStar Bridge Limited (“EU-MCN” or “We”). This Privacy Policy explains how we collect, process, and protect the personal data of our Local Independent Representatives (“Partners”) in full compliance with the EU General Data Protection Regulation (GDPR), despite our operational headquarters being located in Hong Kong, as we provide services to individuals within the European Economic Area (EEA).
The Data Controller responsible for the secure processing of your information is: EuroStar Bridge Limited Kai Tak Fty Building, No.99 King Fuk Street, Sanpokong, Kowloon, Hong Kong S.A.R. Data Protection Officer (DPO) Contact:
info@eu-mcn.com
2. Data Collection and Usage Purposes We process your personal data securely and strictly for the explicit purpose of executing the verification process required by international E-Commerce gateways (e.g., TikTok Shop, Amazon Seller Central, Stripe). 2.1 Information Collected: This includes, but is not limited to, your Full Legal Name, WhatsApp Business Contact Number, Country/City of Residence, and Digital Identification details (such as National ID, Passport scans, and real-time facial biometric verification logs). 2.2 Premium Tier (AI Avatar Data): For Partners who opt into the 300 USDC Premium Tier, we collect standard 2D facial photographs (selfies). This biometric data is utilized solely for training our localized, closed-loop ethical AI models to generate digital avatars for e-commerce product promotion.
3. Legal Basis for Processing (Art. 6 GDPR) Your data processing is legally grounded on:
- Art. 6 (1) lit. b GDPR: Processing is strictly necessary for the performance of a contract (the Trust Agreement/Treuhandvertrag) or for pre-contractual measures (the onboarding KYC phase).
- Art. 6 (1) lit. a GDPR: Processing of biometric data (for the AI Avatar generation) is based on your explicit, voluntary consent provided during the specific Tier 2 application.
4. Secure Third-Party Sharing & KYC Facilitation 4.1 Verification Providers: Your sensitive identification data is securely transmitted explicitly to recognized, bank-grade third-party verification providers (e.g., WebID, IDnow, or platform-native KYC portals) purely for compliance onboarding. 4.2 Merchant Gateways: Necessary details are shared with the respective merchant platforms (TikTok/Amazon) to legally establish the compliant localized store presence. 4.3 Zero Brokerage Guarantee: We absolutely never sell, lease, or distribute your personal data to marketing agencies, data brokers, or unauthorized external third parties.
5. Data Retention Period We retain your personal data only for as long as you maintain an active status as a Local Representative. Standard legal, tax, and commercial retention periods (typically up to 10 years for contractual records) apply to the signed Trust Agreements. Operational KYC data will be purged securely when it is no longer legally required for platform compliance.
6. Your Rights as a Data Subject Under the GDPR, you have the right to request access, correction, deletion (Right to be Forgotten), or restriction of your personal data at any time. You also hold the right to data portability. To exercise these rights to terminate your Partnership, simply contact our compliance team at
info@eu-mcn.com. Upon your verified request and successful offboarding from merchant accounts, your operational data will be permanently purged from our active databases within 30 days.
7. Automated Decision-Making While we utilize AI for content generation (for opted-in Partners), we do not engage in automated decision-making or profiling that produces legal effects concerning you or similarly significantly affects you. All partnership approvals are manually reviewed by our compliance team.