Release Date: [2025-08-25]

Effective Date: [2025-08-25]

Preface

Messer Griesheim (China) Investment Co., Ltd. (Address: Room 205, 2^nd Floor, No. 29 and 33 Suhong Road, Minhang District, Shanghai, hereinafter referred to as “We”) has always valued the protection of your personal information and is committed to consistently implementing this Privacy Policy to ensure the security of your personal information. When you use the relevant functions or services of the Messer China Website (hereinafter referred to as the “Website”), we will process your personal information in accordance with this Privacy Policy and the relevant provisions of other applicable legal documents.

This Privacy Policy is closely related to your use of our Website. We recommend that you carefully read and understand the entire content of this Privacy Policy, especially ensuring that you are fully aware of and understand the meaning and corresponding legal consequences of the content highlighted in bold font, and make your own appropriate choices based thereon.

We will adhere to the following principles to protect your personal information: the principles of legality, legitimacy, necessity, and good faith; the principles of clear, reasonable, and directly relevant purposes; the principle of minimum necessity; the principle of openness and transparency; the principle of ensuring quality; the principle of being responsible for and ensuring the security of personal information, etc. At the same time, we strive to express ourselves in clear, concise, and easily understandable language, and we use bold font to highlight clauses in this Privacy Policy that are of significant importance to your rights and interests to draw your attention. If you have any questions, comments, or suggestions regarding the content of this Privacy Policy, you can contact us through the contact methods provided herein.

This Privacy Policy will help you understand the following:

1. How We Collect and Use Your Personal Information;

2. How We Use Cookies and Similar Technologies;

3. How We Entrust Processing, Share, Transfer, and Publicly Disclose Your Personal Information;

4. How We Store and Protect Your Personal Information;

5. Your Rights;

6. Liability Statement regarding Third Parties;

7. How This Privacy Policy Is Updated;

8. How to Contact Us.

1. How We Collect and Use Your Personal Information

We hereby specifically remind you that as different users choose to use different functions of the Website, the types and scope of personal information collected and used will vary accordingly. The actual collection and use of your personal information will depend on the functions of the Website you actually use. If, during your use of the Website, you provide us with the personal information of others, please ensure that you have obtained their valid consent.

1.1 Under Which Circumstances We Collect Your Personal Information

1.1.1 When you use the search function on the Website, we collect the keywords you input to search for relevant content and display it to you. If you refuse to provide the aforementioned information, you will not be able to use the search function, but this will not affect your browsing of the Website or using its other functions.

1.1.2 When you subscribe to our blog/news, we collect your name, company (optional), email address, and message (optional) to send you information related to our products or services. If you refuse to provide the aforementioned information, you will not be able to use the blog/news subscription function, but this will not affect your browsing of the Website or using its other functions.

1.1.3 When you leave us an online message, we collect your last name, first name, email address, phone number, company, and the content of the assistance you require in order to understand your needs and provide timely feedback. If you refuse to provide the aforementioned information, you will not be able to use the online message function, but this will not affect your browsing of the Website or using its other functions.

1.1.4 When you submit page/website experience feedback, we collect your experience rating, feedback content, and whether the feedback is about a page or the entire website in order to understand your experience details and suggestions and optimize our products or services. If you refuse to provide the aforementioned information, you will not be able to use the experience feedback function, but this will not affect your browsing of the Website or using its other functions.

1.1.5 When you contact us, we collect your last name, first name (optional), email address, phone number (optional), company, region (optional), industry (optional), status (optional), how you learn about us (optional), and the content of the assistance you require in order to get in touch with you. If you refuse to provide the aforementioned information, we will be unable to contact you, but this will not affect your browsing of the Website or using its other functions.

1.2 How We Use Your Personal Information

To comply with national laws, regulations, and regulatory requirements, and to provide you with relevant functions and services, we will use your information in the following circumstances:

1.2.1 to achieve the purposes described in the “How We Collect Your Personal Information” section of this Privacy Policy;

1.2.2 to report to relevant authorities as required by laws, regulations, or regulatory requirements;

1.2.3 when we intend to use the information for other purposes not specified in this Privacy Policy, we will seek your consent again as required by laws and regulations.

1.3 Exceptions to Consent

According to relevant laws and regulations, in the following circumstances, we may collect and use your personal information without your consent as permitted by law:

1.3.1 necessary for us to perform statutory obligations or statutory duties;

1.3.2 necessary for the conclusion or performance of a contract to which you are a party;

1.3.3 necessary to respond to public health emergencies, or necessary to protect the life, health, and property safety of natural persons in emergency situations;

1.3.4 necessary for the public interest in conducting news reporting, public opinion supervision, and other such activities, within a reasonable scope;

1.3.5 processing personal information that you have voluntarily disclosed or that has otherwise been lawfully disclosed, within a reasonable scope and in accordance with the law;

1.3.6 other circumstances stipulated by laws and administrative regulations.

2. How We Use Cookies and Similar Technologies

Please refer to Messer China Website Cookies Policy.

3. How We Entrust Processing, Share, Transfer, and Publicly Disclose Your Personal Information

3.1 Entrusted Processing

If we involve entrusting a partner to process your personal information to enable them to provide certain functions or services to you on our behalf, we will agree with such partner on the purposes, duration, methods, types of personal information, protection measures, and the rights and obligations of both parties regarding the entrusted processing, and we will supervise the partner’s personal information processing activities. If the partner intends to use your personal information for purposes not entrusted by us, it will separately obtain your consent.

3.2 Sharing

3.2.1 When you use the subscription function / online message function / “Contact Us” function on our Website, we may provide your subscription information (if any), online message information (if any), and the information you filled in “Contact Us” (if any) to our affiliated companies (subject to the affiliated companies actually providing services; you can contact us through the contact methods provided in this Privacy Policy to obtain the specific names and contact details of such affiliated companies) for the purpose of contacting you and helping you resolve your questions or needs. The recipient will store and use your personal information within the aforementioned scope.

We will only share your personal information for lawful, legitimate, necessary, specific, and explicit purposes, and will only share the personal information necessary to provide the functions and services. We will require the recipient to strictly keep the obtained personal information confidential and use it in accordance with the law. The recipient has no right to use the shared personal information for any other purposes, except as otherwise stipulated by laws and regulations or the recipient obtains your consent separately in accordance with the law.

3.2.2 We may share your personal information externally as required by laws and regulations, or pursuant to mandatory requirements from government agencies, regulatory authorities, or judicial authorities.

3.3 Transfer

We generally do not transfer your personal information to external parties. In accordance with laws, regulations, and commercial practices, if we need to transfer personal information due to merger, division, dissolution, declaration of bankruptcy, or other reasons, we will inform you of the name and contact details of the recipient, and simultaneously require the recipient to continue to be bound by this Privacy Policy and assume corresponding obligations and responsibilities. If the recipient changes the original purposes or methods of processing, it shall re-obtain your consent in accordance with laws and regulations.

3.4 Public Disclosure

We will not publicly disclose your personal information, except where we have obtained your consent in accordance with the law.

3.5 Exceptions to Your Consent

According to relevant laws and regulations, in the following circumstances, we may share, transfer, or publicly disclose your personal information without prior consent:

3.5.1 necessary for us to perform statutory obligations or statutory duties;

3.5.2 necessary for the conclusion or performance of a contract to which you are a party;

3.5.3 necessary to respond to public health emergencies, or necessary to protect the life, health, and property safety of natural persons in emergency situations;

3.5.4 necessary for the public interest in conducting news reporting, public opinion supervision, and other such activities, within a reasonable scope;

3.5.5 processing personal information that you have voluntarily disclosed or that has otherwise been lawfully disclosed, within a reasonable scope and in accordance with the law;

3.5.6 other circumstances stipulated by laws and administrative regulations.

4. How We Store and Protect Your Personal Information

4.1 Storage of Personal Information

4.1.1 In accordance with the provisions of laws and regulations, we store the personal information collected and generated within the territory of the People’s Republic of China (for the purpose of this Privacy Policy only, excluding Hong Kong, Macau, and Taiwan, hereinafter referred to as “China”) within China.

4.1.2 Unless otherwise stipulated by laws or administrative regulations, we will only store your personal information for the minimum period necessary to achieve the processing purposes. After the aforementioned retention period expires, we will delete or anonymize your personal information. If the retention period stipulated by laws or administrative regulations has not expired, or if deletion or anonymization of personal information is technically difficult to achieve, we will cease processing except for storage and taking necessary security protection measures.

4.2 Protective Measures for Personal Information

4.2.1 The security, integrity, and confidentiality of your personal information are of paramount importance to us. Our Website employs multi-layered technical measures to ensure the security of your personal information. For example, we adopt data encryption technologies, including Transport Layer Encryption (TLS/SSL) and data storage encryption. The transport layer uses the HTTPS protocol to encrypt communication between the user and the server, preventing man-in-the-middle attacks (e.g., phishing WiFi eavesdropping). We also implement access control and authentication technologies; server access requires login via security certificate binding, ensuring that only users holding the key have server access permissions. For session management, session IDs are randomized and automatically expire upon timeout, preventing session hijacking. We have system firewalls in place and perform strict validation on user input (e.g., restricting special characters, data types). We also maintain a Cyber Security Incident Response Team (CSIRT) and utilize Alibaba Cloud’s Cloud Firewall for rapid detection of security incidents.

4.2.2 The internet is not an absolutely secure environment. We will endeavor to ensure the security of any information you provide to us. If our physical, technical, or administrative safeguards are breached, leading to unauthorized access, public disclosure, alteration, or destruction of information, resulting in damage to your legitimate rights and interests, we will bear corresponding legal liability.

4.2.3 If we cease operations, we will promptly stop collecting your personal information, notify you of the cessation of operations individually or by announcement, and delete or anonymize your personal information held by us, unless otherwise stipulated by laws and regulations.

5. Your Rights

In accordance with the relevant laws and regulations of China and other regulatory provisions, we safeguard your right to exercise the following personal information rights:

5.1 Access and Copy Your Personal Information

You have the right to access your personal information, except in circumstances stipulated by laws and regulations. If you wish to access or copy the personal information you generated or submitted while using our Website, please contact us through the contact methods provided in this Privacy Policy. Provided it does not require excessive effort on our part, we will provide it to you within a reasonable scope, unless otherwise stipulated by laws and regulations.

5.2 Correct and Supplement Your Personal Information

When you discover that the personal information we process about you is inaccurate or you need to update your personal information, you have the right to contact us through the contact methods provided in this Privacy Policy to request correction or supplementation.

5.3 Delete Your Personal Information

You have the right to request us to delete your personal information through the contact methods provided in this Privacy Policy in the following circumstances:

5.3.1 the processing purpose has been achieved, cannot be achieved, or is no longer necessary for achieving the processing purpose;

5.3.2 the Website ceases operations, or the retention period has expired;

5.3.3 you withdraw your consent;

5.3.4 we process personal information in violation of laws, administrative regulations, or agreements;

5.3.5 other circumstances stipulated by laws and administrative regulations.

If the retention period stipulated by laws or administrative regulations has not expired, or if deletion or anonymization of personal information is technically difficult to achieve, we will cease processing except for storage and taking necessary security protection measures.

5.4 Delete Your Account

This Website does not offer account registration or login features, and therefore does not involve account management or deletion. If you have any questions regarding this, please contact us using the contact methods provided in this Privacy Policy.

5.5 Transfer Your Personal Information

You have the right to request the transfer of your personal information to a personal information processor designated by you. If such transfer meets the conditions stipulated by the national cyberspace administration authority, such as the ability to verify your true identity, the information being personal information you consented to provide or collected based on a contract, technical feasibility, and no harm to the lawful rights and interests of others, we will provide the means for transfer. If the number of requests for personal information transfer obviously exceeds a reasonable scope, we will charge necessary fees based on the cost of transferring the personal information.

5.6 Change the Scope of Your Authorization and Consent and Withdraw Authorization

Regarding our collection and use of your personal information, you may grant or withdraw all or part of your authorization at any time. If you wish to withdraw consent for blog/news subscriptions, you can do so by unsubscribing through the settings in the email. For other withdrawal requests, please contact us using the contact methods provided in this Privacy Policy. Once consent is withdrawn, we will cease to collect, process, or use the corresponding personal information, and we will be unable to provide you with some functions and services. However, your decision to withdraw consent will not affect the processing of your personal information that was conducted based on your previous authorization.

5.7 Ensure Your Personal Information Rights Are Responded

If you wish to exercise other statutory rights regarding your personal information, such as restricting its processing, please contact us using the contact methods provided in this Privacy Policy.

To ensure the security of your personal information, you may need to submit a written request or otherwise verify your identity when exercising these rights. We reserve the right to verify your identity before processing your request. Unless there are special circumstances, we will accept and process your request within 15 business days.

We generally do not charge fees for reasonable requests. However, if you make repeated requests that exceed a reasonable limit, we may charge a fee based on the circumstances. We reserve the right to reject requests that are groundlessly repetitive, require excessive technical effort, jeopardize the lawful rights and interests of others, or are otherwise impractical.

If you are dissatisfied with our personal information protection security or discover any issues, you can file a complaint or report through the contact methods provided in this Privacy Policy. Unless there are special circumstances, we will accept and process your complaint or report within 15 days.

6. Liability Statement regarding Third Parties

Please note that the third-party websites you visit and the services provided by third parties accessed through us (if any) are subject to their own privacy policies, not this Privacy Policy. When you visit third-party websites or use third-party services, it is recommended that you review and understand their privacy policies. If you identify any risks associated with these third-party websites or services, it is advisable to discontinue the relevant activities to protect your legal rights.

7. How This Privacy Policy Is Updated

7.1 Based on national laws and regulations, the needs to provide functions and services, and business operations, we may partially or wholly revise this Privacy Policy. The modified content will be notified to you through appropriate means. Notably, for significant changes, we will provide more prominent notice.

7.2 Significant changes referred to in this Privacy Policy include:

7.2.1 our name and contact methods;

7.2.2 purposes and methods of processing personal information, the types of personal information processed, and the retention period;

7.2.3 methods and procedures for you to exercise your statutory rights;

7.2.4 other matters that should be informed as stipulated by laws and administrative regulations.

7.3 You have the right to choose whether to continue authorizing us to collect, process, and use your personal information. Please make your choice based on your full understanding of our modified Privacy Policy. If you do not agree to the modified Privacy Policy, you have the right and should immediately cease using our functions and services.

8. How to Contact Us

If you have any questions, comments, or suggestions regarding the content of this Privacy Policy, you can contact us via the following methods:

Email: privacy@messer.com.cn

Address: Room 205, 2^nd Floor, No. 29 and 33 Suhong Road, Minhang District, Shanghai

Generally, we will accept and process your questions, comments, or suggestions within 15 business days. If you are dissatisfied with our response, particularly if you believe our personal information processing activities have infringed upon your lawful rights and interests, you may file a complaint or report with regulatory authorities, such as the cyberspace administration authorities, or initiate legal proceedings in the people’s court where we are registered.