Legal Documentation

Privacy Policy

This Privacy Policy describes how Coolway Refrigeration (Kendall Tech) collects, uses, and protects your personal information when you interact with our website and services.

Effective Date: January 1, 2025
Last Updated: January 1, 2025
Applicable Globally
Section 01

Who We Are

Coolway Refrigeration is the international brand of Kendall Tech Co., Ltd., established in 1999 and headquartered in China. We are an intelligent cold chain solution integrator specializing in the planning, design, manufacturing, installation, and commissioning of cold storage and refrigeration systems for clients worldwide.

For the purposes of this Privacy Policy, "Coolway Refrigeration," "we," "us," and "our" refer to Kendall Tech Co., Ltd. and its affiliated entities operating under the Coolway Refrigeration brand.

We act as the data controller for personal information collected through our website, marketing activities, and business operations. If you have questions about how we handle your data, please refer to the contact information in Section 12.

Section 02

Information We Collect

We collect information in the following categories, depending on how you interact with us:

Business Contact Information

  • -Full name and job title
  • -Company name and industry
  • -Business email address
  • -Phone number
  • -Country and region

Project Inquiry Information

  • -Project type and scope
  • -Temperature and capacity requirements
  • -Project location and timeline
  • -Budget range (if provided)
  • -Technical specifications

Website Usage Data

  • -IP address and approximate location
  • -Browser type and version
  • -Pages visited and time spent
  • -Referring website or search terms
  • -Device type and operating system

Communication Records

  • -Email correspondence
  • -Chat or messaging history
  • -Meeting notes and call records
  • -Trade show or event interactions
  • -Support ticket content

We do not intentionally collect sensitive personal data (such as government IDs, financial account details, or health information) through our standard business processes. If such information is required for a specific contractual purpose, it will be collected under a separate, explicit agreement.

Section 03

How We Use Your Information

We use the information we collect for the following business purposes:

  • Responding to inquiries and project consultations -- processing your contact form submissions, RFQ requests, and technical questions related to cold storage projects.
  • Delivering EPC and engineering services -- managing project contracts, design coordination, equipment supply, installation supervision, and commissioning activities.
  • After-sales support and remote monitoring -- providing IoT-based system monitoring, technical support, and spare parts coordination for installed systems.
  • Business development and marketing communications -- sending relevant industry updates, product announcements, and solution introductions to verified business contacts who have expressed interest or consented to receive communications.
  • Website improvement and analytics -- understanding how visitors use our website to improve content, navigation, and user experience.
  • Legal and regulatory compliance -- fulfilling obligations under applicable laws, export control regulations, trade compliance requirements, and responding to lawful requests from authorities.
Section 04

Legal Basis for Processing

For users located in the European Economic Area (EEA), United Kingdom, and other jurisdictions with similar data protection frameworks, we process your personal data on the following legal bases:

Contract

Processing is necessary to perform a contract with you or to take steps at your request before entering into a contract (e.g., processing a project inquiry or fulfilling an EPC agreement).

Legitimate Interest

Processing is necessary for our legitimate business interests, such as responding to business inquiries, conducting B2B marketing to relevant industry professionals, and improving our website -- where these interests are not overridden by your rights.

Consent

Where required by law, we will obtain your explicit consent before processing your data for marketing communications or non-essential cookies. You may withdraw consent at any time.

Legal Obligation

Processing is required to comply with applicable laws, regulations, or lawful orders from competent authorities, including export control, tax, and trade compliance obligations.

Section 05

Sharing & Disclosure

We do not sell, rent, or trade your personal information to third parties. We may share your information in the following limited circumstances:

  • Service Providers: Trusted third-party vendors who assist us in operating our website, managing CRM systems, sending emails, or providing IT infrastructure. These providers are contractually bound to protect your data and may only use it for the specified purpose.
  • Project Partners and Subcontractors: In the context of delivering EPC services, we may share relevant contact and project information with engineering subcontractors, equipment suppliers, or local installation partners who are directly involved in your project.
  • Legal and Regulatory Authorities: When required by applicable law, court order, or regulatory obligation, we may disclose information to competent authorities, including customs, export control bodies, or law enforcement agencies.
  • Business Transfers: In the event of a merger, acquisition, or sale of all or part of our business assets, your information may be transferred as part of that transaction, subject to equivalent privacy protections.
  • With Your Consent: In any other circumstance where you have provided explicit consent for us to share your information with a specific third party.
Section 06

International Data Transfers

As a global cold chain solution provider operating across Southeast Asia, Africa, the Middle East, Central Asia, Oceania, Europe, North America, and South America, your personal information may be transferred to and processed in countries outside your country of residence, including China where our headquarters is located.

When transferring personal data internationally, we implement appropriate safeguards to ensure an adequate level of protection, which may include:

  • Standard Contractual Clauses (SCCs) approved by the European Commission or equivalent authorities
  • Binding Corporate Rules or equivalent inter-company data transfer agreements
  • Adequacy decisions where applicable
  • Your explicit consent for specific transfers where required

You may request a copy of the applicable transfer mechanism by contacting us using the details in Section 12.

Section 07

Data Retention

We retain personal data only for as long as necessary to fulfill the purposes for which it was collected, or as required by applicable law. Our general retention guidelines are as follows:

Data Category Retention Period
General website inquiries (no project) 2 years from last contact
Active project and contract records Duration of project + 7 years
After-sales support and warranty records Warranty period + 5 years
Financial and invoicing records As required by local tax law (typically 7-10 years)
Marketing consent records Until consent is withdrawn
Website analytics data 26 months (aggregated/anonymized)

When data is no longer required, it is securely deleted or anonymized in accordance with our data disposal procedures.

Section 08

Cookies & Tracking Technologies

Our website uses cookies and similar tracking technologies to enhance functionality and analyze usage. We use the following types of cookies:

Essential
Always Active

Required for the website to function properly, including session management, security, and load balancing. Cannot be disabled.

Analytics
Optional

Used to understand how visitors interact with our website (e.g., pages visited, session duration). Data is aggregated and anonymized where possible.

Marketing
Optional

Used to deliver relevant content and track the effectiveness of our marketing campaigns across platforms. Only activated with your consent.

You can manage your cookie preferences through your browser settings or our cookie consent tool. Note that disabling certain cookies may affect the functionality of our website.

Section 09

Your Rights

Depending on your country of residence, you may have the following rights regarding your personal data. We are committed to honoring these rights in accordance with applicable law:

Right of Access
Request a copy of the personal data we hold about you.
Right to Rectification
Request correction of inaccurate or incomplete data.
Right to Erasure
Request deletion of your data where no overriding legal basis exists.
Right to Restriction
Request that we limit how we process your data in certain circumstances.
Right to Portability
Receive your data in a structured, machine-readable format.
Right to Object
Object to processing based on legitimate interests, including direct marketing.

To exercise any of these rights, please contact us using the information provided in Section 12. We will respond to verified requests within 30 days. You also have the right to lodge a complaint with your local data protection supervisory authority.

Section 10

Security Measures

We implement industry-standard technical and organizational security measures to protect your personal data against unauthorized access, disclosure, alteration, or destruction. Our security practices include:

  • SSL/TLS encryption for all data transmitted between your browser and our servers
  • Access controls and role-based permissions limiting data access to authorized personnel only
  • Regular security assessments and vulnerability testing of our systems
  • Employee training on data protection and information security practices
  • Data backup and disaster recovery procedures
  • Contractual data protection obligations imposed on all third-party service providers

While we take all reasonable precautions, no method of transmission over the internet or electronic storage is 100% secure. In the event of a data breach that poses a risk to your rights and freedoms, we will notify you and the relevant authorities in accordance with applicable legal requirements.

Section 11

Third-Party Links

Our website may contain links to third-party websites, partner portals, industry directories, or social media platforms. These links are provided for your convenience and informational purposes only.

We have no control over the content, privacy practices, or security of third-party websites. This Privacy Policy does not apply to any external sites. We encourage you to review the privacy policies of any third-party sites you visit before providing personal information.

Our website may also integrate third-party tools such as analytics platforms, live chat services, or social sharing widgets. These tools may collect data independently in accordance with their own privacy policies.

Section 12

Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or the way we handle your personal data, please contact our Data Privacy team. We are committed to addressing your inquiry promptly and transparently.

Data Controller
Kendall Tech Co., Ltd.
International Brand: Coolway Refrigeration
China (Est. 1999)
Privacy Inquiries
Response within 30 business days
Available in English, Chinese, and other languages upon request
Policy Updates: We reserve the right to update this Privacy Policy periodically to reflect changes in our practices, technology, legal requirements, or business operations. When we make material changes, we will update the "Last Updated" date at the top of this page and, where appropriate, notify you by email or through a prominent notice on our website. Your continued use of our website or services after any changes constitutes your acceptance of the updated policy.