As of [08-29], 2024 What's new?
1. SUBJECT MATTER AND SCOPE OF APPLICATION
We take the protection of your personal data very seriously. With this Privacy Policy,
we inform you which personal data we collect and how and for what purposes it is processed. We always treat
your personal data in accordance with the statutory data protection regulations and this Privacy Policy.
2. CONTROLLER AND DATA PROTECTION OFFICER
Controller is:
TEK (HONG KONG) SCIENCE & TECHNOLOGY LIMITED
Room 1202, Capital Center, 5-19 Jardine's Barzaar, Causeway Bay, HK China
(hereinafter „Tineco“).
The controller's data protection officer (representative) is:
Name: LUCID Compliance GmbH
Ledererstrasse 19
80331 Munich
Germany
If you have any questions about data protection, you can contact our data protection
officer at any time.
3. VISITING OUR WEBSITE
3.1 Log Files
Each time you visit our website, our system automatically collects data and information
from the computer system of the calling computer. The following data is logged:
- IP address of the calling computer
- Operating system of the calling computer
- Browser version of the calling computer
- Name of the retrieved file/website
- Date and time of retrieval
- Transferred amount of data
- Referring URL
This data is processed in order to be able to present the website, to ensure the
security, availability and integrity of the website (e.g., detection and defense against DoS attacks or access
by bots), to improve the quality and presentation of the website, to be able to identify and correct errors
and for statistical purposes.
Our website is hosted by a service provider named Shopify International Ltd., the
headquarter of which is located in Canada.
The legal basis for this data processing is Art. 6 (1) lit. f) GDPR. Our overriding
legitimate interest is the above purposes.
3.2 Content Delivery Network for the Website
We use a Content Delivery Network (CDN) to increase the security and delivery speed of
the website. A CDN is a network of servers distributed worldwide that is capable of delivering optimized
content to users. For this purpose, personal data may be processed in server log files by the provider of the
CDN.
The provider of the CDN acts as a data processor for us on the basis of a data
processing agreement pursuant to Art. 28 GDPR.
Since a CDN represents a network of servers distributed worldwide, the use of a CDN may
result in the transfer of personal data to a third country without an adequate level of data protection. In
this case, we ensure that appropriate safeguards are provided for the transfer in accordance with Art. 46
GDPR. We will provide you with proof of the appropriate safeguards (Standard Contractual Clauses) at any time
upon request.
The legal basis for this data processing is our legitimate interest pursuant to Art. 6
(1) lit. f) GDPR. Our overriding legitimate interest is to increase the security and delivery speed of the
website.
4. CONTACTING US
If you contact us, e.g., by e-mail, via a contact form, live chat, telephone or other
information transmission tools, the information you provide will be stored for the purpose of processing the
request.
We need the information requested in a contact form or live chat to process your
request, to address you correctly and to send you a reply.
The legal basis for this data processing is Art. 6 (1) lit. f) GDPR. Our overriding
legitimate interest is the communication with prospects, visitors, and customers. If the purpose of the
contact is to conclude a contract, legal basis for processing is Art. 6 (1) lit. b) GDPR.
We process the data of our customers, service providers and suppliers as part of the
provision of our contractual services. In this context, inventory data (for example, surname and first name of
the contact person(s), address), contact data (for example, e-mail address, telephone number), contract data
(for example, subject matter of the contract, term), payment and shipping data (if applicable, such as payment
amount, payment method information, user name, billing and/or shipping address), communication records and
other data collected in the context of the provision of services and/or required for the provision of services
are processed, if applicable. Inquiries and customer relations are regularly stored and processed in our CRM
system. To process your request, we are using Sobot, provided by北京智齿众服技术咨询有限公司 located in China. The
information collected will be used to provide and improve our customer services. If the problem you meet would
obtain a clearer description by taking a photo/screenshot, you may also consider sending to the customer
service such pictures or audios.
Inquiries and customer relations are regularly stored and processed in our CRM system.
The data processed in this context (surname, first name, title, postal address, date of birth if applicable,
your specific interest with regard to our products and services and your interactions with us) may also be
used by us for direct marketing purposes, in particular for postal advertising, in compliance with the legal
requirements.
The legal basis for this storage and processing is our legitimate interest pursuant to
Art. 6 (1) lit. f) GDPR. Our overriding legitimate interest is the marketing of our products and services and
the maintenance of our prospect, customer and service provider relationships
5. E-MAIL NEWSLETTER
5.1 Registration
On our website, you can register to receive a newsletter by e-mail. During registration,
the data from the input mask, the IP address of the calling computer and the date and time of registration are
transmitted to us. For the processing of the data, your consent is obtained during registration and reference
is made to this Privacy Policy.
The registration for the newsletter can be terminated at any time by using the
unsubscribe link contained in each newsletter or by contacting us at the above contact details.
The legal basis for the processing of data after registration for the newsletter is your
consent pursuant to Art. 6 (1) lit. a) GDPR.
We would like to point out that in the event of a withdrawal of the consent, we will
retain the data relating to consent until expiry of the statutory limitation period (pursuant to Section 195
of the German Civil Code (BGB), three calendar years after the last e-mail newsletter was sent) in order to be
able to defend ourselves legally if necessary. The accountability obligation takes precedence over the
deletion obligation here for this period (Art. 17 (3) lit. e) GDPR). The legal basis for this retention of
consent data is Art. 6 (1) lit. c) in conjunction with Art. 5 (1) lit. a), (2), Art. 7 ( 1) GDPR and Art. 6
(1)= lit. f) GDPR.
5.2 Email Newsletter for Existing Customers
If you have concluded a product or service contract with us and provide your e-mail
address, we may use your email address to send direct advertising for our own similar goods or services. You
can object to the use of your e-mail address at any time, without incurring any costs other than the
transmission costs according to the basic rates, by using the unsubscribe link contained in every newsletter
or by contacting us at the above-mentioned contact details.
The legal basis for sending the newsletter as a result of the sale of goods or services
is our legitimate interest pursuant to Art. 6 (1) lit. f) GDPR.
We would like to point out that, in case of an objection to further marketing use and if
your data has already been used for sending e-mail marketing in the context of an existing customer
relationship, we will retain the data on the existence of the requirements of Section 7 (3) of the German
Unfair Competition Act (UWG) until the expiry of the statutory limitation period (pursuant to Section 195 of
the German Civil Code (BGB), three calendar years after the last advertising e-mail was sent) in order to be
able to defend ourselves legally if necessary. The accountability obligation takes precedence over the
deletion obligation here for this period (Art. 17 (3) lit. e) GDPR). The legal basis for this retention of
consent data is Art. 6 (1) lit. c) in conjunction with Art. 5 (1) lit. a), (2), Art. 7 ( 1) GDPR and Art. 6
(1)= lit. f) GDPR.
5.3 Newsletter Service Provider
We may use external service provider as a data processor for sending and analyzing our
newsletter on the basis of a data processing agreement pursuant to Art. 28 GDPR.
This may involve the transfer of personal data to a third country outside the EU without
an adequate level of data protection.
In this case, we ensure that appropriate safeguards are provided for the transfer in
accordance with Art. 46 GDPR. We will provide you with proof of the appropriate safeguards (Standard
Contractual Clauses) at any time upon request.
6. Digital Advertising & Analytics
We may partner with advertising networks and other advertising serving providers
(“Advertising Providers”) that may push advertisements on our behalf and others within the website or to your
email account with the consent of you. Some of these advertisements may be personalized based on your user
profiling. This type of advertising is known as interest-based advertising. We will distinct advertisements
with an “ad” imprint on all advertisements for your ease of identification.
We involve Advertising Providers to identify advertising that might be of interest for
you and/or for products that can be used with your Device and to present them to you within the website and to
analyze the effectiveness of our advertisements presented in the website and your interactions with them. This
information will not be used to identify you personally, but to analyze it in a pseudonymized way. This
technology enables us to pursue our legitimate interests to present you advertisements that suit your
individual interests and to perform direct marketing campaigns for our products and services to our customers.
You may opt-out from such personalized advertising, by using the "Do Not Track" or
relevant functions of a supporting browser, by deactivating the execution of script code in your browser or
through other methods as described in this Privacy Policy or those of the service providers. Please note that
electing to opt out will not prevent advertisements from appearing in your browser or applications. However,
opting out will allow the advertisements pushed to you to be irrelevant to your interests.
7. COOKIES AND THIRD-PARTY TOOLS/FUNCTIONS
Our website uses cookies and implements third-party tools and functions.
Cookies are pieces of information that are transferred from our web server or
third-party web servers to your browser and stored there for later retrieval. Cookies may be small files or
other types of information storage. Information is stored in cookies that is related to the specific end
device used. Cookies contain a characteristic string of characters that enables the browser to be uniquely
identified when the website is called up again. A cookie also contains information about its origin and the
storage period. However, this does not mean that we gain immediate knowledge of your identity.
We also use third-party tools and functions, for example, to expand the functional scope
of the website, to analyze the use of the website, and to optimize the content accordingly.
When integrating tools and functions from third-party providers, personal data may be
transmitted to the providers of the integrated tools and functions in order to be able to provide the tools
and functions.
Cookies and third-party tools and functions are referred to uniformly below as "cookies"
for the sake of simplicity.
7.1 Essential and Non-Essential Cookies
When visiting our website, cookies are set that are absolutely necessary for the
operation of the website. These essential cookies may be, for example, cookies that are required for the
display of the website with a content management system, which are used to recognize language settings, or
which are used to document whether you have consented to the setting of further (non-essential) cookies or
whether you have rejected them.
The technically necessary cookies, including their purpose and storage period or
deletion period, are explained to you in our cookie banner, which is displayed when you access the website.
The legal basis for the processing of personal data using essential cookies is our
legitimate interest pursuant to Art. 6 (1) lit. f) GDPR. Our overriding legitimate interest are the operation
and provision of our website.
We also use non-essential cookies, for example to collect additional information about
the interests of visitors to our websites or about their usage behavior, in order to analyze and optimize our
website and generally our customer interactions on this basis.
Non-essential cookies, including their purpose and storage period or deletion period,
are also explained to you in our cookie banner, which is displayed when you access the website.
Non-essential cookies are only set if you have expressly consented to the setting of
non-essential cookies. You can also select different categories of non-essential cookies that you wish to
allow in the cookie banner.
When using non-essential cookies, the legal basis for the storage and reading of
information is § 25 (1) TTDSG (or in Austria § 96 (3) TKG) and, with regard to the processing of personal
data, Art. 6 (1) lit. a) GDPR.
7.2 Description of the Cookies
7.2.1 Consent Management
On our website, we use the cookie consent management tool Pandectes to obtain your
consent to store certain cookies in your browser and to document this in accordance with the relevant data
protection law. The provider is Cybot A/S , with its registered seat in Denmark (hereinafter Cookiebot).
When you enter our website, a cookie is stored in your browser, in which the consents
you have given or the revocation of these consents are being stored. This data is not shared with the service
provider. You can change the settings by managing your cookie preferences.
The legal basis for this data processing is initially Art. 6 (1) lit. f) GDPR, the
provision of our website and ensuring the possibility to obtain consent for non-essential cookies. If you give
consent, the legal basis for the processing of the data relating to your consent is Art. 7 (1) and 6 (1) lit
a) GDPR.
7.2.2 Google Tag Manager
On our website we use the tool Google Tag Manager. Google Tag Manager is provided by
Google Ireland Limited in Ireland. Through this tool, website tags can be managed via an interface. Google Tag
Manager only implements tags, but no cookies are used, and no personal data is collected. Google Tag Manager
triggers other tags, which in turn may collect data, but Google Tag Manager does not access this data.
7.2.3 Web Analytics und Marketing
We use web analytics services to understand how our website and our Platform are used by
their visitors or users and to optimize the website and the Platform in terms of content and technology.
Google Analytics
We use the web analytics service Google Analytics with IP anonymization. Google
Analytics is a web analytics service provided by Google Ireland Limited ("Google").
JavaScript tags allow us to collect information about your use of the website and the
Platform. Google Analytics also regularly uses cookies to collect information about a user's interactions with
the website or Platform.
Within the scope of the use of Google Analytics, your IP address and information about
the use of the website or Platform, browser type and version, operating system used, the previously visited
page and the time of the server request are transferred to Google servers and processed there.
Within the scope of IP anonymization, the collected IP addresses of users within the
European Economic Area are shortened before being transmitted to the USA. Only in exceptional cases, in the
event of technical malfunctions in Europe, will the unabbreviated IP address be transmitted to Google in the
USA and shortened there. The transmitted IP addresses are not merged with other data from Google.
Google will act for us as a processor on the basis of a data processing agreement
pursuant to Art. 28 GDPR.
As explained, this may involve the transfer of personal data to a third country without
an adequate level of data protection. In this case, we ensure that appropriate safeguards are provided for the
transfer in accordance with Art. 46 GDPR. We will provide you with proof of the appropriate safeguards
(Standard Contractual Clauses) at any time upon request.
The legal basis for this data processing is your express consent pursuant to Art. 6 (1)
lit. a) GDPR.
Tracking Pixel
Tracking pixels from various providers are used on our website to track website usage
and the actions of website visitors for the purpose of conversion tracking. Tracking pixels from the following
providers may be used: LinkedIn, Bing, Meta, Google Ads, Outbrain, Pinterest, Snapchat, Taboola, TikTok,
Twitter/X, Yahoo Native (Gemini).
Tracking pixels are a code snippet that allows us to track the actions of website
visitors, which further allows us to personalize and improve our advertisements and measure their success.
This allows us to evaluate our website for statistical and market research purposes and optimize advertising
campaigns.
The data collected via the tracking pixels may be used by the providers of the
respective pixels for their own tracking and advertising purposes. For further details, please refer to the
privacy statements of the providers of the respective pixels.
If you are a member of a social media platform of one of the providers of the tracking
pixels and have allowed the respective provider to do so via the settings of your user account with the social
media network, the provider of the social media network or the tracking pixel may link the information
collected about your visit to our website to your user account with the respective social media network and
use it for the targeted placement of advertisements.
We can also measure the effectiveness of advertisements on the respective social media
networks and see whether a user was redirected to our website via such ads (conversion measurement).
The integration of such tracking pixels may result in the transfer of personal data to a
third country without an adequate level of data protection. In this case, we ensure that appropriate
safeguards are provided for the transfer in accordance with Art. 46 DSGVO. We will gladly provide you with
proof of the appropriate guarantees (standard contractual clauses) at any time upon request.
The legal basis for this data processing is your express consent pursuant to Art. 6 (1)
a) DSGVO.
7.2.4 Fonts (Google Fonts)
In order to display the content of our website correctly and graphically appealing
across browsers, we use the font library Web Fonts of Google Ireland Ltd. in Ireland (hereinafter “Google”).
When you call up a website on which a font library is integrated, the required font is loaded into the browser
cache in order to display texts and fonts correctly. In doing so, the operator receives the information that
the font required for our website or platform was called up from your IP address.
You can prevent the use of such libraries and the associated data transmission by
installing a JavaScript blocker (e.g. www.noscript.net). If the use of Web Fonts is not supported or
prevented, a default font will be used by your computer.
Google acts for us as a data processor on the basis of a data processing agreement
pursuant to Art. 28 GDPR.
This may involve the transfer of personal data to a third country without an adequate
level of data protection. In this case, we ensure that appropriate safeguards are provided for the transfer in
accordance with Art. 46 GDPR. We will provide you with proof of the appropriate safeguards (Standard
Contractual Clauses) at any time upon request.
The legal basis for this data processing is your express consent pursuant to Art. 6 (1)
lit. a) GDPR.
7.2.5 Videos (YouTube)
YouTube videos are embedded on our website. These are provided, via a plugin, by Google
Ireland Ltd. in Ireland ("YouTube").
We use the "extended data protection settings" for embedded YouTube videos, this means
that YouTube does not set any cookies.
Nevertheless, when you visit a website with the YouTube plugin, a connection to YouTube
is inevitably established and your IP address is transmitted to YouTube in the process.
When using YouTube, personal data is transferred to a third country outside the EU. We
ensure that suitable guarantees are provided for the transfer in accordance with Art. 46 GDPR. We will be
happy to provide you with proof of the appropriate guarantees (Standard Contractual Clauses/Standard Data
Protection Clauses) at any time upon request. To do so, please contact us using the contact details above.
Further information on data protection at YouTube can be found in YouTube's Data
Protection and Security Centre:
https://support.google.com/youtube/topic/2803240?hl=de&ref_topic=6151248
The legal basis for this data processing when using YouTube is Art. 6 (1) lit. f) GDPR.
Our legitimate interest is the integration of videos and the associated optimization of the interactivity of
our website and our customer interactions.
7.2.6 Google reCAPTACHA
On our website, we use the reCAPTCHA service of Google Ireland Limited in Ireland. With
reCAPTCHA, we determine whether a person or a computer makes a certain entry in a form. Google uses the
following data to check whether a person or computer makes an entry: IP address of the end device used, the
website that is visited on our site and on which the captcha is embedded, the date and duration of the visit
to the website, information on the browser and operating system type used, the Google account if the user is
logged in to Google, mouse movements on the reCAPTCHA areas and tasks in which images are to be identified.
This may involve the transfer of personal data to a third country without an adequate
level of data protection. In this case, we ensure that appropriate safeguards are provided for the transfer in
accordance with Art. 46 GDPR. We will gladly provide you with proof of the appropriate We will provide you
with proof of the appropriate safeguards (Standard Contractual Clauses) at any time upon request.
The legal basis for the data processing is our legitimate interest pursuant to Art. 6
(1) lit. f) GDPR. Our overriding legitimate interests are the operation, provision and security of our
website, specifically the protection against automated entries and attacks.
7.2.7 Friendly Captcha
On our website, we use the service Friendly Captcha, provided by Friendly Captcha GmbH
in Germany. With Friendly Captcha, we determine whether a person or a computer makes a certain entry in a
form. As part of this process, Friendly Captcha captures the IP address of the requesting end device in order
to send a cryptographic task to the end device. This task is solved in the background and once solved, a
confirmation is sent by Friendly Captcha to the server that the user is a natural person and not a bot.
Friendly Captcha uses the following data to check whether a person or a computer is making an entry:
Anonymized IP address of the requesting computer, information about the browser used, as well as operating
system, anonymized counter per IP address to control the cryptographic tasks, website from which the access
took place (so-called referer URL).
For more information about data processing and data protection at Friendly Captcha,
please see the Privacy Policy of Friendly Captcha at ttps://friendlycaptcha.com/en/privacy.
The legal basis for the data processing is our legitimate interest according to Art. 6
(1) lit. f) GDPR. Our overriding legitimate interests are the operation, provision and security of our
website, specifically the protection against automated entries and attacks.
7.2.8 Geotargeting
We use the IP address and other information provided by the user (in particular postcode
as part of registration or ordering) to address regional target groups (so-called "geotargeting").
The regional target group approach is used, for example, to automatically show you
regional offers or advertising that are often more relevant for users. The legal basis for the use of the IP
address and, if applicable, other information provided by the user (in particular postal code) is Art. 6 (1)
(f) GDPR, based on our interest in ensuring a more precise target group approach and thus providing offers and
advertising with higher relevance for users.
In doing so, part of the IP address as well as the additional information provided by
the user (in particular postal code) are only read out data.
You can prevent geo-targeting, for example, by using a VPN or proxy server that prevents
accurate localization. In addition, depending on the browser used, you can also deactivate location
localization in the corresponding browser settings (as far as the respective browser supports this).
8. SOCIAL MEDIA
8.1 Social Media Buttons
Social media buttons of various social media networks (e.g. Linkedin, Instagram,
Twitter/X, Facebook and TikTok) are integrated on our website.
If you click on one of these social media buttons, you will be redirected to our pages
on the respective social media network. In this case, the provider of the respective social media network
receives the information that your browser has accessed the corresponding page of our website, even if you do
not have a profile with the respective social media network or are not logged in there. This information
(including your IP address) is transmitted by your browser directly to a server of the respective provider. If
you click on a social media button and are either logged in to the respective social media network or then log
in to the page of the respective social media network, the transmitted information can be assigned to your
account with the social media network.
For information on the purpose and scope of data collection and processing by the
providers of the respective social media network, the provider identification, a contact option and your
rights and setting options for data protection, please refer to the respective privacy policy of the providers
of the social media networks. The legal basis for the integration and use of social media buttons is Art. 6
(1) lit. f) GDPR. Our overriding legitimate interest is the marketing of our offers and our website.
8.2 Social Media Pages
We maintain a publicly accessible profile on various social media networks (e.g.
Linkedin, Instagram, Twitter/X and Facebook).
If you visit our social media pages and are logged in to the respective social media
network, the provider of the respective social media network can analyze your usage behavior and assign the
information collected to your account with the social media network and enrich it there. Even if you are not
logged in or if you do not have an account with the respective social media network, personal data may be
collected by the provider of the respective social media network, for example your IP address or data
collected via a cookie.
The operators of the social media networks can use this data to create user profiles.
Based on your user profile, you can then be shown interest-based advertisements both on the websites of the
social media network and on other websites.
If you visit one of our social media pages, we are jointly responsible with the provider
of the social media network for the collection and processing of your personal data that takes place there.
For information on the collection and processing of your personal data that takes place there, we refer you to
the privacy policy of the respective social media network.
You can assert your data subject rights in accordance with Chapter III. of the GDPR
(right to information, correction, deletion, restriction of processing, data portability, etc.) both against
us and against the provider of the respective social media network. In this context, we would like to point
out that we can only influence the processing of personal data and the implementation of data subject rights
within the framework of our social media pages within the scope of the possibilities made available to us by
the respective provider.
The legal basis for our use of social media pages is Art. 6 (1) lit. f) GDPR. Our
overriding legitimate interest is the presence and marketing of our products and services on the Internet.
9. COMPETITIONS/SWEEPSTAKES
When participating in one of our offline or online competitions/sweepstakes, we collect
and process the personal data provided by the participant as part of the participation in the competition,
usually first name, address and e-mail address.
We collect this data in order to enable participation in the competition, to carry out
the competition, to inform the participant of a prize, if applicable, and to send the participant a possible
prize.
We process the participants' personal data to conduct the competition and to determine
and notify the winners.
Insofar as participants provide information as part of their participation that is not
required for participation in the respective competition, this is done on a voluntary basis.
If you do not provide us with the data required to participate in a competition, it will
not be possible to participate in the competition or to contact you regarding notification of a prize.
The legal basis for data collection and data processing is the performance of the
contract according to Art. 6 (1) lit. b) GDPR.
10. MERGERS AND ACQUISITIONS (M&A)
If we are involved in a restructuring, acquisition, asset sale, merger, financing,
transfer of services to another provider, due diligence, insolvency or receivership, your personal data may be
transferred to third parties to the extent legally permitted in connection with and as part of the relevant
legal process, subject to the basic principles of data protection law.
11. AGE RESTRICTION
This website is not intended or designed for use by children under the age of 16 (or
other age as a child pursuant to the laws and regulations in your jurisdiction). We do not knowingly collect
personally identifiable information from or about anyone under the age of 16. If you are a child or minor
pursuant to the laws and regulations of the place in which you reside, we recommend you to ask your parents or
guardians to read this Policy and use our services or provide your information to us with the prior consent
from your parents or guardians. If your guardians do not allow you to use our services or provide your
information to us according to this Policy, please stop using our services immediately and give a notice on
time so that we can react accordingly. If, due to reasons out of our control such collection occurs, we will
remove such information once we are notified. We will keep personal data collected confidential and safe in
accordance with the relevant laws and regulations.
12. RECIPIENTS OF DATA
Within our company, those internal departments or organisational 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.
Data will only be passed on to third parties within the framework of legal requirements.
We will only pass on your data to third parties if, for example, this is necessary for contractual purposes on
the basis of Art. 6 (1) lit. b) GDPR or to safeguard our overriding legitimate interest pursuant to Art. 6 (1)
lit. f) GDPR in the effective conduct of our business operations. Examples include fulfilling orders for
products or services, delivering packages, sending postal mail and email, analyzing data, providing
marketing assistance, providing search results and links, processing payments, transmitting content, and
providing customer service. These third-party service providers have access to personal data needed to
perform their functions, but may not use it for other purposes. Specifically, we currently involve cloud
services providers to host the website and store data in Germany, to collect information about the crash
history of the website and your using behavior and to send out push notifications. The legal basis is Art. 6
(1) b) GDPR.
There are also cases where we are required to provide your personal data to the
competent supervisory authorities pursuant to the Law, court orders, any other provisions of legal
proceedings, or mandatory requirements imposed by administrative or judicial bodies. Information sharing
under this circumstance may not require your prior authorization or consent. Insofar we are required to
provide your personal data under legal obligations. The legal basis for such disclosure of your information
will be Art. 6 (1) c) GDPR. For other cases of disclosure of your personal data, the legal basis for such
disclosure will be Art. 6 (1) f) GDPR.
Third parties to whom we may, or is obliged to, transfer personal data on the basis of
the above, can be located in another country subject to prior establishment of additional guarantees acc
ording Art. 44 et seq. GDPR.
Specifically, we use below third-party providers such as plugins and content delivery
networks on our website for various purposes.
Service |
Provider |
Transfer to third countries |
Purposes of data processing |
Information on data protection and appropriate safeguards for third country transfers |
Alibaba Cloud CDN |
Alibaba Group Holding Limited |
China |
Content Delivery Networks |
https://www.alibabacloud.com/help/en/legal/latest/alibaba-cloud-international-website-privacy-policy
|
Cookiebot |
Cybot A/S |
Denmark |
Cookie-Consent |
https://www.cookiebot.com/de/privacy-policy/ |
Google Analytics |
Google Ireland Ltd.. |
Ireland (USA) |
Tracking |
https://policies.google.com/privacy?gl=DE&hl=de https://business.safety.google/gdpr/ |
Klaviyo |
Klaviyo, Inc. |
USA |
Email Marketing |
https://www.klaviyo.com/legal/privacy/privacy-notice |
SmartLook |
Smartlook.com, s.r.o. |
Czech Republi |
Data Analysis and Tracking |
https://help.smartlook.com/docs/privacy-policy |
Sobot |
北京智齿众服技术咨询有限公司 |
China |
Customer Service Platform |
https://www.sobot.com/en/privacy-protection-policy.html |
Insofar as we use service providers within the framework of the provision of the website
and/or Platform or other services, we take appropriate legal precautions as well as appropriate technical and
organisational measures to ensure the protection of your personal data.
13. CROSS-BORDER TRANSFER OF PERSONAL DATA
Since we provide products or services based on our resources and servers worldwide, your
personal data might be transmitted to a jurisdiction or accessed from a jurisdiction outside of the country
where you reside. Such destination jurisdictions include: (i) the jurisdiction where your personal data is
stored (if it is the same as where you are located (cross-border transfer does not apply); (ii) China, where
our affiliates’ registered office, our affiliates which are involved in our Websites products and services and
most of our service providers, are located, and when our employees need to have access to your personal data
for handling your issues and also conducting general analysis; (iii) the storage location of some other
service providers which serve you on behalf of us through their API integrated into the Website, mostly at
your local jurisdictions, or at the jurisdiction where their relevant branch resides to specifically serve
your local jurisdiction; and (iv) some other jurisdictions from where your Website account was once logged in,
provided that the data storage location for such jurisdiction differs from your domicile country.
Specifically, if you send to data-privacy@tineco.com an email, your personal data contained in such email and
its delivery will be directed to China, where our email-box server is located. All such international
transfers are made in connection by and between the relevant servers housed in third-party cloud facilities
and physically located in such jurisdictions, and we will require third-party cloud suppliers to adopt
appropriate safeguards in compliance with the Law.
14. YOUR RIGHTS
You have the rights explained below with regard to the personal data processed by us
concerning you:
14.1 Right of Access
You can request information in accordance with Art. 15 GDPR about your personal data
that we process.
14.2 Right to Rectification
If the information concerning you is not (or no longer) accurate, you may request a
correction in accordance with Art. 16 GDPR. If your data is incomplete, you may request that it be completed.
14.3 Right to Erasure
You may request the erasure of your personal data in accordance with Art. 17 GDPR.
14.4 Right to Restriction of Processing
In accordance with Art. 18 GDPR you have the right to request restriction of processing
of your personal data.
14.5 Right to Object to Processing
You have the right to object at any time on grounds relating to your particular
situation to the processing of your personal data which is carried out on the basis of Art. 6 (1) lit. e) or
lit. f) GDPR in accordance with Art. 21 (1) GDPR. In this case, we will not further process your data unless
we can demonstrate compelling legitimate grounds for the processing which override your interests, rights
and freedoms, or if the processing serves to assert and exercise or defend against legal claims (Art. 21 (1)
GDPR).
In addition, according to Art. 21 (2) GDPR, you have the right to object at any time
to the processing of personal data concerning you for the purposes of direct marketing; this also applies to
any profiling, insofar as it is related to such direct marketing.
14.6 Right to Withdraw Consent
Insofar as you have given your consent for processing, you have a right to withdraw your
consent pursuant to Art. 7 (3) GDPR.
14.7 Right to Data Portability
You have the right to receive the personal data concerning you that you have provided to
us in a structured, common and machine-readable format ("data portability") as well as the right to have this
data transferred to another controller if the conditions of Art. 20 (1) lit. (a) and (b) GDPR are met.
14.8 Exercise of Rights
You can exercise your rights by notifying the above contact details for the data
controller or the data protection officer.
14.9 Right to Complain to the Data Protection Authorities
If you believe that our processing of your personal data violates data protection law,
you also have the right to complain to a data protection supervisory authority of your choice pursuant to
Article 77 of the GDPR.
15. RETENTION AND DELETION
We adhere to the principles of data avoidance and data economy and only store your
personal data for as long as is necessary to achieve the respective purpose of the data processing purposes or
as stipulated by the storage periods provided by law.
If the purpose of storage no longer applies or if a storage period provided for by law
expires, the personal data will be routinely anonymized or deleted in accordance with the statutory
provisions.
16. INFORMATION SECURITY
We take appropriate technical and organizational measures in accordance with the state
of the art to ensure a level of protection for the personal data we process that is appropriate to the risk of
the respective processing and to protect the data we process against accidental or intentional manipulation,
loss, destruction or against access by unauthorized persons.
Our website uses SSL encryption for security reasons and to protect the transmission of
confidential content, such as orders, inquiries or payment data that you send to us.
Our employees receive regular training on data protection and information security and
are committed to confidentiality and data protection.
A restrictive rights and roles concept on a "need to know" basis ensures that employees
only have access to the personal data they absolutely need to perform their duties.
17. AMENDMENT OF THIS PRIVACY POLICY
We reserve the right to amend this Privacy Policy from time to time so that it always
complies with current legal requirements and/or in order to implement changes to our services in the Privacy
Policy, e.g. when introducing new services. When visiting the website or using our services, the current
privacy policy always applies.