1. The Program

2. Categories of your personal data that we may process in this Program

3. How we store and protect your personal data

4. How we entrust, share, transfer and disclose your personal data

5. How we safeguard your rights and interests regarding your personal data

At the recruitment stage, we will issue an announcement to inform you of the specific information of the Program. If you intend to participate in our Program, please provide us with the information in accordance with the announcement. Once you click the “Agree” button and submit your information, you will be deemed as giving consent to join our Program, and agreeing that we may contact and utilize the information in the table as set out in Section 2 of this Statement.

At the participants screening and communicating stage, we will review your submission in accordance with specific requirements as indicated in the Program announcement after receiving the information you have submitted. Without your explicit consent, such data will not be used to recognize the identity of you or any other individuals, or for any other purposes.

If the Posts you provided were eligible, we will contact you according to the contact details you have provided to inform with you about the arrangements in the next stages and the notification of the Prizes. To express our appreciation to you for your support to this Program, we will provide the participants with eligible Posts with exclusive points or other diversified rewards. Please see our Terms and Conditions for more details.

We may collect, use or disclose certain data from you at different stages respectively in this Program as described in below table. We ensure you that such data will not be used for any purposes other than those disclosed to you in this Statement or otherwise permitted by the applicable laws and regulations.

* Note: Due to the objective needs of this Program and in certain occasional situations, we may not entirely rule out the possibility of collecting, using, or disclosing some of your personal data when we announce the participants who win the Prizes of this Program on the website. To protect your privacy and avoid processing your personal data by accident, we will use technical methods commonly adopted in the industry to anonymize your data and ensure that it is difficult to identify or relate to any specific individuals from the anonymized data.

•  Special provision on privacy of minors

We would like to remind you that, minors under the age of 18 (or if you are a minor pursuant to the laws and regulations where you reside) are not included as the targeted group of this Program. In case we occasionally collected data related to minors, such data will be deleted immediately. If you find that we have collected data of minors, please feel free to contact us under the contact information listed in Section 5 of this Statement. Upon recipient, we will delete the relevant data in time after we have reviewed and confirmed the collection.

Since the business operation team who support in this Program are based in our headquarters located in the People’s Republic of China (P.R.C), your personal data we have collected in this Program will be transferred and stored in P.R.C.

You understand and agree that when you click to submit the data, you will be deemed to have fully understood and agree that your personal data will be transferred outside your jurisdiction and stored in China. If you refuse such transfer, you should immediately stop submitting relevant data.

We will take necessary and reasonable data security protection measures when transferring your personal data outside your jurisdiction on the premise of providing appropriate safeguards in accordance with the data security requirements in your jurisdiction. These measures include but are not limited to signing standard contractual clauses approved by the European Commission in accordance with the General Data Protection Regulation (the GDPR) and / or the applicable laws in your jurisdiction, data encryption or de-identification methods, etc. You may contact us through the contact channel disclosed in this Statement to know more about the protection measures related to the international transfer of your personal data.

We will store the data submitted by you for the period necessary to fulfill the purposes outlined in this Statement or required or permitted by the applicable laws and regulations. If the data you provided become unnecessary to achieve the above purpose, we will delete or anonymize the data provided without delay.

We undertake to maintain data security to the level as specified by the Law. In order to keep your data safe, we commit to apply various security technologies and associated management systems to protect your data from being disclosed, destroyed or lost. We have established our personal data protection department. We have also developed relevant internal policy to strictly control data access procedures and approval mechanisms. We seek to only give employees who may access to your data the least authority and limited data access sufficient for fulfilling their duties.

Please understand that due to the limitation of technologies or potential malicious attacks, personal

data security incidents may unfortunately occur due to factors beyond our control. If an incident occurs, we will, in accordance with laws and regulations, immediately notify you of: general facts and potential influences of the incident, measures we have adopted or will adopt, advice for you to protect your data and reduce risks, our remedial measures for you, etc. We will inform you by email, letter, telephone or by pushing notifications. If we cannot contact you individually, we will publish notifications in a reasonable and effective manner. We will also report the result of personal data security incident to regulatory departments if required.

Within our company, those internal departments or organizational units receive your data which they need to fulfil their tasks, to fulfil contracts with you if necessary, for data processing with your consent or to safeguard our overriding legitimate interests.
For the purposes of this Program, below listed the third parties who we may disclose your personal data to, and who can obtain and/or process your personal data. We undertake to prompt such service providers to abide by the applicable laws and process your personal data only for the purposes listed in this Statement.
The following authorized customer service provider entrusted will involve the handling of your data which are necessary to provide the delivery services to you.

i. Klaviyo
Company name, location: Klaviyo, Inc., USA
Processing activities: Send you the notification of the Program and the information of the Prizes.
What type of data is accessed: Email address.
How the third party processes the data: According to your authorization in this Statement and our instructions.
Contacts of third party: privacy@klaviyo.com

ii. Shopify
Company name, location: Shopify Inc., Canada
Processing activities: Use the email address you provide on opening an account or as updated by you from time to time as the primary method for communication with you and providing you with the services.
What type of data is accessed: Email address.
How the third party processes the data: According to your authorization in this Statement and our instructions.
Contacts of third party: 151 O’Connor Street, Ground floor, Ottawa, Ontario, K2P 2L8.

If you need to access, rectify, delete, or restrict or object our processing of any data you have provided, or you want to raise any other requests, please contact data-privacy@tineco.com. We will contact you in a timely manner upon the receipt of your message, and promptly respond to your request.

We fully respect your right to choose. After participating in the Program, you may choose to withdraw your consent to our processing of your personal data or opt out from the Program through data-privacy@tineco.com. Upon receipt of your request to withdraw consent or to opt out, we will promptly contact you and delete all the data you have provided to us during your participation in the Program after we have checked and confirmed your intent to do so.