Personal Information Protection Policy

本政策仅适用于巴斯夫中国提供trinamiX 近红外光谱解决方案

This Policy applies only to trinamiX NIR spectroscopy solution provided by BASF China.


Last update date: 042022.


If you have any queries, comments or suggestions, please contact us via the following means:


Email: support@trinamixsensing.cn


This Policy will help you understand the following:


Rules on collection and use of Personal Information for Business Function


How do we protect your Personal Information


Your rights


How do we process the Personal Information of children


How is your Personal Information transferred globally


This Policy will help you understand the following:


Rules on collection and use of Personal Information for Business Function


How do we protect your Personal Information


Your rights


How do we process the Personal Information of children


How is your Personal Information transferred globally


BASF China is fully aware of the importance of your Personal Information to you, and will do its utmost to protect the security and reliability of your Personal Information. We are committed to maintaining your trust in us, and abide by the following principles in our efforts to protect your Personal Information: commensurability of powers and responsibilities, clear purpose, consent, minimum necessary, security assurance, engagement of Subjects, openness and transparency, etc. In the meanwhile, BASF China undertakes to take appropriate security protection measures to protect your Personal Information according to the established industry-specific security standards.


Please read carefully and understand this Personal Information Protection Policy before using our products or services.


Rules on Collection and Use of Personal Information for Business Function

1、 我们收集哪些您的个人信息

1. What Personal Information do we collect?


Running of this Business Function we provide requires certain information. If you choose to use this Business Function, you need to provide or allow us to collect the following necessary information:

- 身份提供商:通过使用您的身份提供商注册并登录我们的应用服务,您将向我们提供有关您首选的身份提供商信息(例如“微信”)

- Identity Provider: by using your Identity Provider to register and log in to our app service, you give us information about your preferred identity provider (e.g. WeChat)

- 姓名:您将被要求提供您的真实姓名,我们将使用该姓名来创建用户 ID,以确保服务的正常运行

- Name: you will be asked to provide your full name which will be used by us to create a User ID to ensure the normal operation of the service

- 邮件地址:您将被要求提供您的邮件地址,我们将使用该地址创建用户 ID并与您联系,以确保服务的正常运行

- Mail address: you will be asked to provide your mail address which will be used by us to create a User ID and to contact you to ensure the normal operation of the service


A total of 3 types of Personal Information.


When you are using this Business Function, our App will apply to you for the following Personal Information-related system authorizations:

- 互联网接入:我们需要互联网接入以确保我们所提供服务的正常运行。 通过互联网接入,测量数据将传输至云端,在云端进行数据处理。 如果不能接入互联网,则无法将测量数据转化为测量结果。

- Internet access: we need internet access to ensure the normal operation of the service we provide. With internet access, the measurement data is be transferred to the cloud, where the data is processed. It will be not possible to translate measurement data into results without internet access.

- 无线连接/USB/定位:我们需要访问无线连接/USB/定位,以确保我们提供的服务正常运行。 通过无线连接,光谱设备可以连接到您的智能手机/平板电脑,这是将测量数据发送到云端的必要条件。通过您无线连接的访问技术上也可能间接获得关于您的位置的信息,即使我们不会使用功能。

- Wireless connection/USB/Location: we need access to wireless connection/USB/Location to ensure the normal operation of the service we provide. Via wireless connection, the spectroscopy device is connected to your smartphone/tablet, which is needed to send the measurement data to the cloud. By giving access to your wireless connection, it might be technically also possible to indirectly get information about your location, even though we will not use this function.


A total of 2 system authorizations. If you do not grant such authorities, we will become unable to provide this Business Function. In addition to the above authorities, you can elect whether to grant additional system authorities to our App.


Additional and optional authorizations include:

- 照相机/QR-/条形码扫描仪:使用此功能,您将更容易识别和管理要测量的样品

- Camera/QR-/barcode scanner: with this functionality it will be easier for you to identify and manage the samples you want to measure.

- GPS/定位:使用此功能,您将更容易将测量数据标记到特定位置,这在运行历史或地理评估时将具有优势

- GPS/location: with this functionality it will be easier for you to tag your measurement data to a certain location, which will be of advantage when running historic or geographic evaluations.


The authorization of these functions is voluntary and can be withdrawn without comprising of app functionality.

2、 我们如何使用您的个人信息

2. How do we use your Personal Information

对于必要的个人信息,我们会用来提供该项业务功能,包括分配个人用户 ID,联系您以便您访问应用程序和隐私声明的修订 我们也会使用上述信息来维护和改进本项业务功能,开发新的业务功能等。未经事先同意,我们不会使用您的个人信息作广告用途。

We will use the necessary Personal Information to provide this Business Function, including assigning an individual User ID and contacting you to give you access to the app and changes of privacy note, as well as to maintain and improve this Business Function, develop new Business Functions, and so forth. We will not use your personal information for advertising purposes without prior consent.

3、 我们如何委托处理、共享、转让、公开披露您的个人信息

3. How do we delegate the processing, sharing, transfer, and public disclosure of your Personal Information

(1) 共享

(1) Sharing


We will not share your Personal Information with any company, organization or individual other than this Company and Affiliates of this Company unless we have obtained your Explicit Consent. “Affiliate” shall mean, with respect to this Company, any entity which, directly or indirectly, controls, is controlled by or is under the common control with the Party. An entity shall be deemed to control another person if the controlling person possesses, directly or indirectly, ownership of at least fifty percent (50%) of the equity shares of such an entity or has the power to direct the management of such an entity. In the following cases, we will seek consent from you before sharing your Personal Information:

a) 如果在登陆或用户注册方面存在严重问题,我们可能会在征得您的明确同意后,转移以下个人信息:

If there are some serious issues for onboarding or user registration, we might, after your explicit consent, transfer the following personal information:

– 姓名

– Name

– 邮件地址

– Mail address

– 身份提供商

- Identity Provider

我们将仅与 trinamiX GmbH (位于德国)共享数据,该公司与巴斯夫中国同受巴斯夫欧洲公司控制/拥有

We will share the data only with trinamiX GmbH (located in Germany), who is under the same control/ownership of BASF SE with BASF China.


We may share your Personal Information externally in accordance with laws and regulations or as required by government authorities.

(2) 转让

(2) Transfer


We will not transfer your Personal Information to any company, organization or individual, except in the following cases:

a) 在获取明确同意的情况下转让:获得您的明确同意后,我们会向其他方转让您的个人信息;

Transfer with Explicit Consent: we may transfer your Personal Information to other parties after obtaining your Explicit Consent;

b) 在涉及合并、收购或破产清算时,如涉及到个人信息转让,我们会在要求新的持有您个人信息的公司、组织继续受此个人信息保护政策的约束,否则我们将要求该公司、组织重新向您征求授权同意。

In case of merger, acquisition or bankruptcy liquidation in which transfer of Personal Information is involved, we will require the new companies or organizations that will hold your Personal Information to continue to be bound by this Personal Information Protection Policy, or alternatively we will require such companies or organizations to seek consent from you again.

(3) 公开披露

(3) Public Disclosure


We will publicly disclose your Personal Information only under the following circumstances:

a) 获得您明确同意后;

Upon obtaining your Explicit Consent;

b) 基于法律的披露:在法律、法律程序、诉讼或政府主管部门强制性要求的情况下,我们可能会公开披露您的个人信息。

Disclosure according to law: We may disclose your Personal Information publicly if required by laws, legal procedures, or litigation or government authorities.


How do we protect your Personal Information

(一)我们已使用符合业界标准的安全防护措施保护您提供的个人信息, 防止数据遭到未经授权访问、公开披露、使用、修改、损坏或丢失。我们会采取一切合理可行的措施,保护您的个人信息。例如通过我们的服务器结构,我们确保所有的服务和存储都托管在中国,以便用户的数据留在中国。

(1) We have employed security protection measures that meet industry standards to protect the Personal Information provided by you and prevent such data from unauthorized access, public disclosure, use, modification, damage or loss. We will take all reasonable and feasible measures to protect your Personal Information. For example, with our server structure we ensure that all services and storages are hosted in China so that the user data stays in China.


(2) We will take all reasonable and feasible measures to ensure that no irrelevant Personal Information is collected. We will retain your Personal Information only for such period as necessary to achieve the purposes specified in this Policy, unless extension of the retention period is needed or permitted by law.


(3) We will regularly update and publish the relevant contents of reports on security risks, personal information security impact assessments and so on. You will be informed by us via App or your given mail address.


(4) The Internet environment is by no means 100% secure. We will do our best to ensure or guarantee the security of any information you send to us. If our physical, technical, or management safeguards are damaged, resulting in unauthorized access, public disclosure, tampering or destruction of any information and therefore causing any damage to your legitimate rights and interests, we will bear the corresponding legal responsibilities therefor.


(5) After any Personal Information security incident occurs, we will inform you of the following in a timely manner as required by laws and regulations: the basic situation and possible impact of the security incident, measures we have taken or will take to handle the incident, suggestions on the steps you can take independently to prevent and reduce any risks, remedies available to you, etc. We will promptly notify you of the incident-related information by email, letter, phone, push notification or other means. Where it is difficult to inform the Personal Information Subjects individually, a public announcement will be released in a reasonable and effective manner.


In the meanwhile, we will report the handling of Personal Information security incidents according to the requirements of regulatory authorities.


Your rights


We will, in accordance with the relevant Chinese laws, regulations and standards, and the common practices in other countries and regions, guarantee that you can exercise the following rights with respect to your Personal Information:


(1) Right of access to your Personal Information


You have the right of access to your Personal Information, except as otherwise provided by laws and regulations. You may exercise the right of access to data in the following way:

(1. a)移动应用程序

(1.a) mobile App

- 打开 trinamiX光谱应用程序

- Open the trinamiX Spectroscopy App

- 使用您的帐户登录

- Sign In with your account

- 点击右下方的齿轮按钮

- Press the gear button on the bottom right

- 点击“账户”

- Press “Account”

(1. b)网络应用程序

(1.b) web App

- 转到nirs.trinamixsensing.cn

- Go to nirs.trinamixsensing.cn

- 使用您的账户登录

- Sign In with your account

- 点击右上方的头像

- Press on your Avatar on the top right

- 选择“个人资料”

- Select “profile”

对于您在使用我们的产品或服务过程中产生的其他个人信息,只要我们不需要过多投入,我们会向您提供。如果您想行使数据访问权, 请发送电子邮件至zhi-hua.liu@trinamix.de

With respect to other Personal Information generated during your use of our products or services, we will provide such information to you as long as this is not excessively onerous for us. If you want to exercise the right of access to data, please send an email to zhi-hua.liu@trinamix.de.


(2) Right to correct your Personal Information

当您发现我们处理的关于您的个人信息有错误时,您有权要求我们作出更正。您可以随时使用我们的 Web 表单联系或发送电子邮件至zhi-hua.liu@trinamix.de。

Where you find any error in your Personal Information processed by us, you have the right to require us to make corrections. you can use our web forms to contact us or send an email to zhi-hua.liu@trinamix.de at any time.


We will respond to your request for correction within 30 days.


(3) Right to delete your Personal Information


You can make a request for deletion of your Personal Information where:


1. Our processing of your Personal Information violates any laws or regulations;


2. We have collected or used your Personal Information without your consent;


3. Our processing of your Personal Information violates the agreement with you;


4. You no longer use our products or services, or you have cancelled your account;


5. We no longer provide products or services for you.


If we decide to respond to your request for deletion, we will also notify the entities that have obtained your Personal Information from us and require them to delete such information in a promptly manner, except as otherwise provided by laws and regulations, or unless these entities have obtained consent from you separately.


Where your Personal Information has been deleted from our service system, we may not delete the corresponding information from the backup system immediately but will instead delete such information when the backup system is updated.


(4) Right to change the scope of your consent


Each Business Function needs certain basic Personal Information to be realized. For the collection and use of additional Personal Information, you can give or withdraw your consent at any time.


You can give or withdraw your consent in the following way:


(4.a) mobile App

- 打开 trinamiX Spectroscopy App

- Open the trinamiX Spectroscopy App

- 使用您的账户登录

- Sign In with your account

- 点击右下角的齿轮按钮

- Press the gear button on the bottom right

- 点击“隐私设置”

- Press “Privacy Settings”

(4. b)网络应用程序

(4.b) web App

- 转至nirs.trinamixsensing.cn

- Go to nirs.trinamixsensing.cn

- 点击底部的 "管理Cookies"

- Press “Manage Cookies” on the bottom


If you withdraw your consent, we will cease processing the corresponding Personal Information. However, your decision to withdraw your consent will not affect our previous Personal Information processing activities carried out under your authorization.


(5) Right of Personal Information Subjects to cancel their accounts


You can cancel your previously registered account at any time in the following way:

(5. a)移动应用程序

(5.a) mobile App

- 重复(1.a)描述的步骤

- Repeat steps described in (1.a)

- 点击 "停用 "按钮

- Press the “Deactivate” button

- 当被问及您是否真的想停用您的账户时,点击 ""

- Press “Yes” when asked if you really want to deactivate your account

(5. b)网络应用程序

(5.b) web App

- 重复(1. b)描述的步骤

- Repeat steps described in (1.b)

- 点击 "停用 "按钮

- Press the “Deactivate” button

- 当问及你是否真的想删除你的账户时,点击 ""

- Press “Yes” when asked if you really want to delete your account


After your account is deleted, we will stop providing products or services for you and retain your personal information in accordance with the "Cybersecurity Law of the People's Republic of China" and other applicable laws and regulations for a retention period required by the laws. Upon the expiration of the retention period, we will remove or anonymize your personal information.


(6) Right of Personal Information Subjects to obtain copies of their Personal Information

您有权获取您的个人信息副本您可以通过以下方式操作:发送邮件至mail to zhi-hua.liu@trinamix.de

You have the right to obtain a copy of your Personal Information in the following way: mail to zhi-hua.liu@trinamix.de


Where technically feasible, if the data interface is matched, we can also transmit a copy of your Personal Information directly to a third party designated by you at your request.


(7) Restrictions on automated decision-making of information systems


In some Business Functions, we may make decisions based solely on non-manual automated decision-making mechanisms including information systems, algorithms, etc. If these decisions significantly affect your lawful rights and interests, you have the right to require us to offer an explanation, and we will also provide appropriate remedies to you.


(8) Responding to your requests


To ensure security, you may need to submit a written request or otherwise prove your identity. We may ask you to verify your identity before processing your requests.


We will respond to your requests within thirty days. If you are dissatisfied with our response, you can also lodge a complaint through the following channels: zhi-hua.liu@trinamix.de


In principle, we do not charge a fee on any reasonable requests made by you, but for repeated requests that exceed reasonable limits, we will charge a certain cost-based fee as appropriate. We may reject unreasonably repetitive requests that require excessive technical means (for example, the development of a new system or fundamental change of existing practices), pose a risk to the legitimate rights and interests of others or are extremely impractical (for example, involving any information stored on backup tapes).


We will be unable to respond to any request submitted by you if:

1、 与个人信息控制者履行法律法规规定的义务相关的;

1. It is related to the performance by the Personal Information Controller of the obligations provided by laws and regulations;


2. It is directly related to national security or national defense;


3. It is directly related to public safety, public health, and significant public interests;


4. It is directly related to criminal investigation, prosecution, trial, enforcement of judgments and the like;


5. The Personal Information Controller has sufficient evidence to prove that the Personal Information Subject is subjectively malicious or has engaged in the abuse of power;


6. It is necessary for protecting the life, property or other major lawful rights and interests of the Personal Information Subject or other individuals, and it is difficult to obtain their consent;


7. Responding to such request would seriously undermine the lawful rights and interests of the Personal Information Subject or other individuals or entities;


8. Trade secrets are involved.


How do we process the Personal Information of children


Our products, websites and services are mainly for adults. Children should not be allowed to create their own Personal Information Subject account without the consent of their parents or guardians.


For the collection of children’s Personal Information with parental consent, we will use or publicly disclose such information only to the extent permitted by law, with the Explicit Consent of their parents or guardians, or where it is necessary for the purpose of protecting the children.

尽管当地法律和习俗对儿童的定义不同,但我们将不满 14 岁的任何人均视为儿童。

Although different laws and customs define a child differently, we treat anyone under 14 years of age as a child.


If we find that we have collected any childs Personal Information without prior verifiable parental consent, we will try to delete the relevant data as soon as possible.


How is your Personal Information transferred globally

原则上,我们在中华人民共和国境内收集和产生的个人信息, 将存储在中华人民共和国境内。

In principle, the Personal Information we collect and generate within the territory of the People’s Republic of China will also be stored within the territory of the People’s Republic of China.


We provide products or services with resources and servers deployed across the world, which means that with your consent, your Personal Information may be transferred to the overseas jurisdictions (countries/regions) where you use our products or services, or be accessed from such jurisdictions.


Such jurisdictions may have different data protection laws, or even have no relevant laws. In such cases, we will ensure that your Personal Information is adequately protected to the same degree it is protected in the People’s Republic of China. For example, we will seek your consent for cross-border transfer of Personal Information, or implement de-identification and other security measures prior to cross-border data transfer.