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Sino Pass SA — Terms of Service

Effective Date: 27 April 2026 | Version 1.0

IMPORTANT: Please read these Terms of Service carefully before using the Sino Pass SA platform. By accessing or using our services, you agree to be bound by these terms.

1. Definitions

In these Terms of Service, the following definitions apply:

  • "Platform" means the Sino Pass SA web application, including all subdomains, dashboards, APIs, and associated services operated by Sino Pass SA.
  • "User" means any individual or legal entity that accesses or uses the Platform, whether as a registered account holder or an unregistered visitor.
  • "Service" refers to any product, feature, or functionality provided through the Platform, including but not limited to the Intelligence Dashboard, Evidence Registration, GACC Concierge Audit, Health Passport, and Enterprise API.
  • "GACC" means the General Administration of Customs of the People's Republic of China.
  • "POPIA" means the Protection of Personal Information Act 4 of 2013 (South Africa).
  • "MRN" means Movement Reference Number, the unique identifier required for customs clearance of agricultural goods entering China.
  • "Content" means any data, documents, files, images, or information uploaded, submitted, or generated by the User on the Platform.

2. Acceptance of Terms

By accessing or using the Platform, you confirm that you have read, understood, and agree to be bound by these Terms of Service. If you do not agree to any part of these terms, you must not access or use the Platform.

By creating an account or submitting any information through the Platform, you represent and warrant that:

  • You are at least 18 years of age or have the legal capacity to enter into a binding agreement.
  • You are acting on behalf of a registered business or as an authorised representative of an agricultural exporting entity.
  • All information you provide is accurate, current, and complete.
  • You will maintain the confidentiality of your account credentials.
  • You will not use the Platform for any unlawful purpose or in violation of any applicable laws or regulations.

3. Description of Services

Sino Pass SA provides a sovereign compliance intelligence platform designed specifically for South African agricultural exporters trading with China. The Platform offers the following core services:

3.1 Intelligence Dashboard (Public)

A publicly accessible dashboard displaying real-time strategic intelligence on China's agricultural import regulations, tariff changes, port clearance metrics, and policy shifts affecting South African exports.

3.2 Evidence Registration

A secure document registration service that allows exporters to upload, hash (SHA-256), timestamp, and store compliance evidence. Each document receives a cryptographic integrity badge, providing verifiable proof that the document existed in its current state at a specific point in time.

3.3 GACC Concierge Audit

A premium service that provides structured compliance audits aligned with GACC import requirements. This service includes document gap analysis, regulatory checklists, and readiness scoring. The GACC Concierge Audit is designed to help exporters prepare for MRN applications and customs clearance.

3.4 Health Passport

A future service tier (currently in development) that will provide end-to-end compliance lifecycle management, including phytosanitary certificate tracking, bilateral protocol compliance, and direct GACC liaison support.

3.5 Enterprise API

API access for enterprise customers requiring programmatic integration with the Platform. Enterprise API usage is governed by a separate Enterprise License Agreement.

4. Compliance Disclaimer — Critical

4.1 No Guarantee of Customs Clearance

Sino Pass SA provides compliance intelligence, document registration, and readiness assessment tools. We do not guarantee that any shipment, product, or exporter will obtain customs clearance, MRN approval, or market access into the People's Republic of China. Customs clearance decisions are the sole prerogative of GACC and other relevant authorities.

4.2 Sovereign Authority

The Platform provides intelligence and guidance based on publicly available information and proprietary analysis. However, GACC regulations, tariff lines, phytosanitary requirements, and port procedures are subject to change without notice. Sino Pass SA cannot be held responsible for changes in Chinese regulatory policy that affect the accuracy or timeliness of our intelligence.

4.3 Intelligence Data Limitations

While we strive to provide accurate and up-to-date intelligence, the Platform's data is sourced from multiple channels and may contain delays, inaccuracies, or omissions. Users should independently verify critical information before making export decisions.

4.4 Document Integrity

The cryptographic integrity badge provided through the Evidence Registration service confirms that a document existed at a specific point in time and has not been altered since registration. It does not constitute a certification, endorsement, or approval of the document's content by Sino Pass SA or any regulatory authority.

5. Payment Terms

5.1 Pricing

Current subscription pricing is as follows:

  • T1 — Standard: R1,850/month — Intelligence Dashboard access, Evidence Registration (up to 50 evidence items/month), unlimited compliance checks, unlimited certificate generation, plus bulk upload, analytics, and priority support.
  • T2 — GACC Concierge: R12,500 one-off (90-day audit window) — Full GACC Decree 280 compliance audit with PDF report, MRN registration guidance, cold-chain mandate verification, and dedicated audit support.
  • T3 — Health Passport: Coming soon — pricing to be announced.

All prices are in South African Rand (ZAR) and exclude VAT where applicable. Sino Pass SA reserves the right to modify pricing with 30 days' notice to active subscribers.

5.2 Payment Processing

Payments are processed securely through our third-party payment processor, PayFast. By subscribing, you authorise Sino Pass SA to charge your selected payment method on a recurring monthly basis. Your subscription will automatically renew unless cancelled before the next billing date.

5.3 Refund Policy

Subscription fees are non-refundable except where required by applicable consumer protection law. If you believe you have been incorrectly charged, please contact us within 14 days of the charge date.

5.4 Failed Payments

If a payment fails, we will attempt to process the payment again within 3 days. If the payment continues to fail, access to paid features will be suspended until the outstanding amount is settled. Continued non-payment may result in account termination after 30 days.

6. Data and Privacy

6.1 Data Sovereignty

Sino Pass SA is a brand, operated by The San Scribe Pty Ltd. All user data is stored in South African data centres (AWS Africa — Cape Town region) unless otherwise specified. We comply with POPIA and all applicable South African data protection laws.

6.2 Data You Own

You retain full ownership of all Content you upload to the Platform. Sino Pass SA does not claim any intellectual property rights over your Content. You grant us a limited license to store, process, and transmit your Content solely for the purpose of providing the Service.

6.3 How We Use Your Data

We use your data to provide, maintain, and improve the Platform; to process transactions; to communicate with you about your account; and to comply with legal obligations. We do not sell your personal information to third parties. For full details, please refer to our Privacy Policy.

6.4 Zoho CRM

We use Zoho CRM to manage customer relationships and communications. By creating an account, you consent to your contact information being stored in Zoho CRM in accordance with Zoho Corporation's privacy practices and POPIA requirements.

7. Intellectual Property

The Platform, including its design, code, algorithms, analytics models, intelligence data, branding, and proprietary content, is the intellectual property of Sino Pass SA and is protected by South African and international intellectual property laws. You may not copy, modify, reverse-engineer, distribute, sell, or create derivative works of the Platform without our prior written consent.

The Sino Pass SA name, logo, and branding are trademarks of Sino Pass SA. All third-party trademarks referenced on the Platform remain the property of their respective owners.

8. Limitation of Liability

To the maximum extent permitted by applicable law:

  • Sino Pass SA shall not be liable for any indirect, incidental, special, consequential, or punitive damages arising out of or relating to your use of the Platform.
  • Our total liability for any claim arising from these Terms or your use of the Platform shall not exceed the total amount paid by you to Sino Pass SA in the 12 months preceding the claim.
  • We are not liable for any loss or damage resulting from: (a) your reliance on Platform intelligence for export decisions; (b) delays or failures in customs clearance; (c) unauthorised access to your account due to your failure to maintain credential confidentiality; (d) third-party service interruptions (including PayFast, Zoho, or AWS outages).

9. Governing Law and Jurisdiction

These Terms of Service shall be governed by and construed in accordance with the laws of the Republic of South Africa. Any disputes arising from these Terms shall be subject to the exclusive jurisdiction of the courts of Cape Town, South Africa.

10. Amendments

Sino Pass SA reserves the right to amend these Terms of Service at any time. Material changes will be communicated to registered users via email and/or a notice on the Platform at least 14 days before the changes take effect. Continued use of the Platform after the effective date of any amendment constitutes acceptance of the revised terms.

11. Contact Details

For questions, concerns, or notices regarding these Terms of Service, please contact us:

Sino Pass SA

Cape Town, South Africa

Email: legal@sinopass.co.za

For sales and general inquiries, please visit our Support Centre.