1. Personal Data
Personal data refers to information that can identify an individual when used alone or in combination with other information. Such data may be submitted by you when using our website, products, or services, or obtained by us through recording how you interact with our website, products, or services, for example, through technologies like cookies. The data we collect depends on the website you visit or the products and services you use and may include personal data such as name, address, email address, phone number, etc. The purpose of collecting personal data is to contact you in order to provide corresponding services or send important notifications, etc.
2. Privacy Policy
Shanghai TTX Information Technology Co., Ltd and its global subsidiaries (hereinafter referred to as "TTX", "we" or "our") fully recognize the importance of personal data to customers and users. Therefore, Shanghai TTX Information Technology Co., Ltd attaches great importance to the protection of personal data of customers and users, and has taken a series of measures to ensure that relevant business complies with applicable personal data protection requirements (such as GDPR).
To ensure effective implementation of personal data protection requirements, Shanghai TTX Information Technology Co., Ltd has appointed a Data Protection Officer (DPO). Shanghai TTX Information Technology Co., Ltd adopts industry-recognized personal data protection methods and practices. In business scenarios where GDPR applies, Shanghai TTX Information Technology Co., Ltd uses the Data Protection Impact Assessment (DPIA) method to assess and mitigate personal data security risks in products and services.
2.1 Shanghai TTX Information Technology Co., Ltd requires a thorough assessment of the personal data involved in products and services, and projects involving personal data must undergo DPIA.
2.2 Projects involving personal data must establish data inventories and data flow diagrams.
2.2.1 Projects involving personal data must be subject to a DPIA;
2.2.2 Data inventories and data flow diagrams must be established for projects involving personal data;
2.2.3 Projects involving personal data must identify potential risks in the data processing stages (including collection, use, storage, sharing, deletion, etc.) and implement appropriate measures (including managerial, physical, and technical measures) based on the risk level.
2.2.4 Upon completion of the DPIA, a corresponding report must be generated and approved by the DPO.
2.3. Shanghai Tong Tian Xiao Information Technology Co., Ltd. has implemented technical measures including intrusion detection, access control, encryption, data loss prevention, anti-spam, endpoint security protection, and vulnerability scanning. The effectiveness of these personal data protection measures is verified through penetration testing.
2.4. Shanghai TTX Information Technology Co., Ltd has established a personal data breach emergency response mechanism. In the event of a personal data breach, Shanghai TTX Information Technology Co., Ltd will immediately initiate the emergency response process, making efforts to minimize the potential losses resulting from the breach and ensure that affected individuals receive appropriate notification.
2.5. Shanghai TTX Information Technology Co., Ltd has established continuous employee privacy policy training mechanisms to ensure that every employee involved in GDPR understands the legal principles of data protection based on their specific job responsibilities and strictly adheres to the applicable company policies and procedures.
2.6. To ensure compliance, Shanghai TTX Information Technology Co., Ltd has implemented necessary personal data protection technology audits and process audits.
Personal data protection is not only a legal requirement but also a corporate social responsibility. Shanghai TTX Information Technology Co., Ltd will continue to optimize products and services to ensure security and privacy, reducing the personal data protection risks for customers and users.
3. Policy Update
Shanghai TTX Information Technology Co., Ltd reserves the right to update or modify this policy from time to time. If there are changes to this policy, we will publish the latest version of the policy here. If we make significant changes to the privacy policy, we may also notify you of the changes through different channels, such as posting notices on our website or sending individual notifications to you.
