Privacy Policy by TecAlliance

Last Updated: April 9, 2024

Effective Date: April 9, 2024

Thank you for your interest in TecAlliance. Data protection has been a particularly high priority for TecAlliance China Ltd. (“TecAlliance” or “We”).

The use of the TecAlliance web catalogue pages needs users to make registration or login. Any collection of personal information during this process will be done with your consent. The processing of personal information will strictly adhere to the provisions of relevant laws and regulations, including the Cybersecurity Law of the People’s Republic of China (the “ Cybersecurity Law”), the Data Security Law of the People’s Republic of China(the “Data Security Law”), and the Personal Information Protection Law of the People’s Republic of China(the “Personal Information Protection Law”).

Through this Privacy Policy, we aim to inform the users about the nature, scope, and purpose of the personal information we collect, use, and process. Additionally, this Privacy Policy will outline the rights enjoyed by individuals as data subjects.

This Privacy Policy will help you understand the following:

1. Definitions

2. How We Collect and Use Your Personal Information

3. How We Protect Your Personal Information

4. How We Entrust, Share, Transfer, and Disclose Your Personal Information

5. Your Rights

6. Authorization and Commitment Guarantee Regarding VIN

7. Cookies

8. Privacy Policy Regarding the Use and Application of Matomo (Piwik) Marketing Suite

9. Protection of Minors

10. Job Applicants

11. Cross-Border Transfers

12. Others

13. Updates to the Privacy Policy

14. How to Contact Us

TecAlliance, as a personal information processor, has implemented numerous technical and organisational measures to ensure that the personal data processed via this website is protected as completely as possible. Nevertheless, Internet-based data transmissions can in principle have security gaps, so that absolute protection cannot be guaranteed. For this reason, we reserve the option to transmit personal information by alternative means, such as telephone.

Please be sure to read and understand this Privacy Policy carefully before using our website services and begin using it after confirming that you fully understand and agree to it. If you do not agree with any of the contents of this Privacy Policy, please do not provide your information upon request and stop using this website. By continuing to use this website, you acknowledge our provisions regarding personal information as described in this Privacy Policy.

1.Definitions

The data protection declaration of TecAlliance is based on the terms which in the enactment of current laws and regulations, including the Cybersecurity Law, the Data Security Law, and the Personal Information Protection Law. Our privacy policy should be easy to read and understand for the public as well as for our customers and business partners. In order to ensure this, we would like to explain the terms used in advance.

We use the following terms in this Privacy Policy:

(1) Personal Information

Personal information refers to any kind of information that can identify the identity of a natural person either independently or in combination with other information as electronically or otherwise recorded. This includes but is not limited to a person’s name, date of birth, identification number, biometric information, address, phone number, etc., excluding information that has been anonymized.

(2) Processing

Processing refers to any operation or series of operations related to personal information carried out with or without the aid of automated processes, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination, or otherwise making available, alignment or combination, restriction, erasure, or destruction.

(3) Sensitive Personal Information

Sensitive personal information refers to personal information that, once leaked or illegally used, will easily lead to infringement of the human dignity or harm to the personal or property safety of a natural person, including biometric recognition, religious belief, specific identity, medical and health, financial account, personal location tracking and other information of a natural person, as well as any personal information of a minor under the age of 14.

(4) Minor

A minor refers to an individual under the age of 18.

(5) Service Log Information

This includes browsing history, click-view records, search query records, as well as IP addresses, browser types, telecommunications service provider locations (city-level), language preferences, access dates and times, and records of web pages visited.

2. How We Collect and Use Your Personal Information

2.1 Collection and Use of General Data and Information

The TecAlliance website collects a series of general data and information each time the website is accessed by a person or an automated system. This general data and information are stored in the log files of the server and includes (1) browser types and versions used, (2) the operating system used by the accessing system, (3) the website from which an accessing system accesses our website (so-called referrer), (4) the sub-sites which are accessed via an accessing system on our website, (5) the date and time of access to the website, (6) an Internet protocol address (IP address), (7) geographical region (city-level) of the Internet service provider of the accessing system; and (8) text content entered into search boxes, such as vehicle identification numbers (VINs), brand part numbers, original equipment manufacturer (OEM) part numbers, etc. This information is used to avert dangers in the event of attacks on our information technology systems.

When using this general data and information, TecAlliance does not draw any conclusions about the person concerned. This information is needed (1) to optimise the content and display logic of our website, (2) to refine our website’s advertising strategy (3) to ensure the long-term functionality of our information technology systems and the technology of our website meets market demand, (4) to provide law enforcement authorities with the information necessary for law enforcement in the event of a cyberattack, and (5) to enhance the accuracy of TecAlliance’s vehicle identification based on VIN decoding. Overall, this collected data and information is therefore evaluated by TecAlliance both statistically and with the aim of increasing data protection and data security in our company to ultimately ensure an optimum level of protection for the personal data processed by us. The anonymous data of the server log files are stored separately from all personal information provided by the person concerned and will be deleted once it is no longer needed for its collection purpose.

2.2 Registration and Use of TecAlliance Services

Due to the nature of the content or services provided on this website, we require users to register to access our services. To provide additional features of our products and/or services, you may choose to consent or decline our collection and use of your information separately. If you refuse to provide such information, you may not be able to access certain additional features or achieve the desired functionality, but it will not affect your use of our basic features.

The functionalities we offer include:

A. Registration: To create a TecAlliance web catalogue account, you need to provide at least your email address and login password. If you refuse to provide the above information, you will be unable to register for a TecAlliance web catalogue account or use the TecAlliance web catalogue. Other information such as phone number, company, and address are optional. This information will help us to contact you more quickly in special circumstances.

The personal information you provide to us through registration on the TecAlliance web catalogue will be collected and stored solely for internal use and our own purposes as personal information processors, such as statistical analysis of registered user numbers, distribution of user types, distribution of user industries, and geographic distribution analysis of users.

By registering on this website, the registration date and time assigned to you by your internet service provider (ISP) will be stored. The storage of this data is aimed at preventing misuse of our services by malicious actors, and if necessary, this data can be used to assist in criminal investigations. In this regard, the storage of this data is necessary for the protection of the personal information processor. This data will not be disclosed to third parties unless required by law or for criminal prosecution purposes.

B. Search: When you use the search function (including photo search), we will collect your search history, including search content (such as VINs), browsing records/time, and search time/frequency.

To provide efficient search services, some of the aforementioned information, such as searched VINs, will be temporarily stored on your local device and displayed to you as a search history.

Individual search term information cannot identify your identity, and we have the right to reasonably use it for other purposes.

2.3 Other Rules

If the information you provide contains personal information of other users, you must ensure that you have obtained legal authorization before providing us with such personal information.

Additionally, according to relevant laws, regulations, and national standards, we may process your relevant personal information without obtaining your authorization under the following circumstances:

(1) Necessary for performing a statutory responsibility or statutory obligation;

(2) Necessary for the conclusion and performance of a contract to which you are a contracting party;

(3) Necessary for responding to a public health emergency, or for protecting the life, health or property safety of the natural person in the case of an emergency

(4) Where the personal information, which has already been disclosed by the individual or otherwise legally disclosed, is processed within a reasonable scope and in accordance with the law;

(5) Any other circumstance as provided by law or administrative regulations.

3. How We Protect Your Personal Information

3.1 Storage of Personal Information and Data

Personal information will be retained within the statutory retention period or as stipulated in contracts. After this period, the corresponding personal information will be routinely deleted or anonymised unless it is still required for contract fulfilment or initiation.

Personal information generated or collected within the territory of the People’s Republic of China will be stored within the territory of the People’s Republic of China. Our website operations and technical teams are located within the territory of the People’s Republic of China. We will strictly adhere to security protection measures in accordance with laws and regulations, as well as this Privacy Policy, to protect your rights.

3.2 Information Protection Technology Measures

We employ standard security measures to protect users’ personal information, preventing data from being attacked, destroyed, lost, used, accessed without authorization, publicly disclosed, or otherwise negatively affected. We will also take a series of reasonable measures to protect your personal information. We use SSL encryption to protect data exchange and provide HTTPS on our website to ensure data confidentiality. Trusted protection measures are employed to prevent any data from malicious attacks. Access control mechanisms are set up to ensure that only authorized personnel can access your personal information.

3.3 Response to Personal Information Security Incidents

We strongly advise you to set a complex and secure password and refrain from sending your personal information through any unencrypted channels. We will make every effort to protect your data security, employing reasonable methods and following relevant laws. However, the internet environment is complex and may be subject to malicious attacks. This means we cannot guarantee the absolute security of information, and by agreeing to access the internet, you acknowledge its risks. We appreciate your understanding and will always strive to protect your rights to the fullest extent.

In the event of a personal information security incident, such as damage to our physical, technical, or managerial protection facilities resulting in unauthorized access, disclosure, tampering, or destruction of information, leading to damage to your legitimate rights and interests, we will promptly initiate an emergency plan and take reasonable and necessary measures to minimize the impact on you as an individual. If a personal information security incident occurs, we will inform you of the basic situation and potential impacts of the security incident, the measures we have taken or will take, suggestions for you to prevent and reduce risks, and remedial measures available to you in accordance with legal requirements. We will inform you through SMS, phone calls, push notifications, and other reasonable channels. If it is difficult to inform you individually, we will publish announcements through reasonable and effective means. Additionally, if necessary, we will report the handling of personal information security incidents to regulatory authorities as required.

4. How We Entrust, Share, Transfer, and Disclose Your Personal Information

4.1 Entrustment Processing

Certain specific modules or functions within our business operations are provided by external suppliers. For example, we may hire service providers to assist us in providing customer support.

For companies, organizations, and individuals entrusted with processing personal information on our behalf, we will sign strict confidentiality agreements with them, requiring them to handle personal information in accordance with our requirements, this Privacy Policy, and any other relevant confidentiality and security measures.

4.2 Sharing

We will not share your personal information with any company, organization, or individual outside of our company unless we obtain your explicit separate consent.

We may share your personal information externally in accordance with legal and regulatory requirements or mandatory requests from government regulatory authorities.

4.3 Transfer

We will not transfer your personal information to any company, organization, or individual unless under the following circumstances: (1) Transfer with explicit consent: With your explicit consent, we will transfer your personal information to other parties; (2) In cases of mergers, acquisitions, or bankruptcy liquidations involving the transfer of personal information, we will require the new entity holding your personal information to continue to be bound by this Privacy Policy, or else we will require the new entity to seek your authorization again.

4.4 Disclosure

We will only disclose your personal information in the following circumstances: (1) After obtaining your explicit consent; (2) Based on legal disclosure: We may disclose your personal information in accordance with legal procedures, litigation, or mandatory requests from government regulatory authorities.

5. Your Rights

5.1 Inquiry of Personal Information

You have the right to inquire about your personal information, except in cases specified by relevant laws and regulations. If you wish to inquire about your personal information, please contact the TecAlliance team by emailing “sales_cn@tecalliance.net”.

5.2 Correction of Personal Information

If you discover errors in your personal information during processing, you have the right to request correction. You can contact the TecAlliance team by emailing “sales_cn@tecalliance.net” to process your request.

5.3 Deletion of Personal Information

You can request the deletion of your personal information from our backend by emailing “sales_cn@tecalliance.net” to contact the TecAlliance team. We will process your request and provide feedback.

5.4 Account Cancellation

You can cancel your account by emailing “sales_cn@tecalliance.net”. We will assist you in cancelling your account.

Please note that once the account is cancelled, we will cease our related services or products.

5.5 Situations Where We Cannot Respond to Your Requests

· Related to national security.

· Related to public and people’s safety.

· Related to criminal investigations, prosecutions, and tracking.

· If you abuse your rights.

· If it will adversely affect other organizations or individuals.

You have the responsibility to protect your personal information while using any products and services, and you should be cautious of any form of fraud.

Please do not disclose your information to unrelated institutions.

Do not use others’ information as your own.

If you violate your responsibilities and cause adverse effects and losses to others, you should bear the risk yourself. In this regard, we will not respond to any issues caused by you.

6. Authorization and Commitment Guarantee Regarding VIN

In accordance with the Personal Information Protection Law and relevant laws, regulations, and regulatory requirements, VINs of sold vehicles fall within the scope of personal information. Therefore, TecAlliance has established the following provisions regarding the input of VINs. Please read and understand the following carefully:

6.1 When using our web catalogue service through the TecAlliance website, you must carefully read this Privacy Policy, accept, and agree to all terms before using our web directory service.

6.2 If the VIN you input belongs to the vehicle registered under your name, you authorize and consent to TecAlliance processing that VIN.

6.3 If the VIN you input does not belong to the vehicle registered under your name but is entered for the purpose of vehicle maintenance, and the owner authorizes you to input the VIN to inquire about related spare parts, you promise and guarantee that you have obtained the owner’s authorization and will conduct inquiries within the scope authorized by the owner.

6.4 If the VIN you input does not belong to the vehicle registered under your name and you have not obtained any authorization, you promise and guarantee not to use our web catalogue service for inquiries. In such cases, you agree that TecAlliance has the right to refuse to provide web catalogue services to you. If your query violates current laws and regulations of China, we reserve the right to pursue your legal responsibility. If necessary, we will report to relevant regulatory enforcement departments.

7 Cookies

The TecAlliance website uses cookies. Cookies are text files which are stored on a computer system via an Internet browser.

Many websites and servers use cookies. Many cookies contain a so-called cookie ID. A cookie ID is a unique identifier of the cookie. It consists of a string of characters through which Internet pages and servers can be assigned to the specific Internet browser in which the cookie was stored. This enables the visited Internet pages and servers to distinguish the individual browser of the person concerned from other Internet browsers that contain other cookies. A specific Internet browser can be recognized and identified via the unique cookie ID.

By using cookies, TecAlliance can provide users of this website with user-friendly services that would not be possible without the setting of cookies.

By means of a cookie, the information and offers on our website can be optimised in the interests of the user. Cookies enable us, as already mentioned, to recognize the users of our website. The purpose of this recognition is to make it easier for users to use our website. For example, the user of a website that uses cookies does not have to re-enter his access data each time he visits the website because recognition is performed by the website and the cookie is stored on the user's computer system. Another example is the cookie of a shopping cart in the online shop. The online shop remembers the items that a customer has placed in the virtual shopping cart with a cookie.

Users can prevent the setting of cookies on our website at any time with the appropriate setting of the Internet browser used. It will permanently prevent the setting of cookies. Furthermore, cookies that have already been set can be deleted at any time via an Internet browser or other software program. This is possible in all common Internet browsers. If a person deactivates the setting of cookies in the Internet browser used, not all functions of our website may be fully usable under certain conditions.

We will not use Cookies for any purpose more than those described in this data protection policy. You can manage and delete Cookies based on your preferences, also can clear all cookies which saved in your computer (most of web browsers have Cookie blocking capabilities).

8. Privacy Policy Regarding the Use and Application of Matomo (Piwik) Marketing Suite

TecAlliance has integrated the Matomo (Piwik) Marketing Suite component on this website.

The Matomo (Piwik) Marketing Suite collects first-party information of website visitors based on cookies, IP addresses, and browser fingerprints. It creates user profiles based on browser history and calculates metrics related to website usage, such as bounce rate, visit intensity, and page views.

The Matomo (Piwik) Marketing Suite servers are deployed within the territory of the People’s Republic of China.

All traceable data is outlined here: https://matomo.org/faq/general/faq_18254/

All cookies used by the Matomo (Piwik) platform are listed here: https://matomo.org/faq/general/faq_146/

More information and the current privacy policy of Matomo (Piwik) can be found on the following website: https://matomo.org/privacy-policy/

9. Protection of Minors

Our products and services are primarily intended for adults, and minors without parental consent should not create their own accounts.

We value and pay attention to the protection of personal information of minors, and we also expect parents or guardians to guide minors in using our services.

Although the definition of children may vary according to local laws and customs, we consider anyone under the age of 14 as a child.

If you are a child, we recommend that you ask your parents or guardians to carefully read this Privacy Policy and use our services or provide personal information to us only after obtaining their consent. In cases where personal information of children is collected with the permission of parents or guardians, we will only use, share, transfer, or disclose this information in accordance with the law, with the explicit consent of parents or guardians, or when necessary to protect the children.

We do not intentionally collect the personal information of children for any purpose. If we find that we have collected personal information of children without obtaining verifiable consent from parents or guardians, we will make efforts to delete the relevant data as soon as possible; if you are a parent or guardian of a user and wish to withdraw consent, please contact us, and we will delete such information.

10. Job Applicants

This applies where applicants submit personal information to TecAlliance as part of the application process, e.g. on paper, by email, or by applying a third party recruitment service provider's electronic form. TecAlliance will apply the personal information volunteered by the applicant to the recruitment process.

If you send us an application document, either in writing or electronically, which does not correspond to any recruitment information, you agree that your personal information data will be stored with us for consideration of future recruitment information.

11. Cross-Border Transfers

In principle, personal information collected and generated within the territory of the People’s Republic of China will be stored within the territory of the People’s Republic of China. However, due to our use of resources and servers located globally to provide products or services, your personal information may be transferred to jurisdictions outside the country/region where you use the product or service, or accessed from such jurisdictions, with your consent.

Such jurisdictions may have different data protection laws or may not have relevant laws at all. In such cases, we will ensure that your personal information receives an equivalent level of protection as it would in the People’s Republic of China. For example, we may request your separate consent for cross-border transfer of personal information or implement security measures such as data anonymization before transferring data across borders.

12 Others

12.1 Third-Party Links and Related Policies

This website may contain links to other websites, which may be owned or operated by third parties and/or their affiliates. They may collect your personal information and may be located in the People’s Republic of China or other countries/regions, with servers located in these countries/regions. We cannot control nor are we responsible for the privacy policies and data protection policies of any such third parties and their affiliates. We strongly advise you to review the privacy policies and data protection policies of all such third parties and their affiliates to understand how they will handle the personal information they may collect from you.

12.2 Basis of Personal Information Processing

We reiterate that providing personal information is, to some extent, required by law (such as tax regulations) and may also result from contractual provisions (such as information about business partners). Sometimes, for the purpose of entering into a contract, relevant individuals may need to provide us with personal information, which must subsequently be processed by us. For example, when our company enters into a contract with a party, the party is obligated to provide us with personal information. Failure to provide personal information means that a contract cannot be signed with you. Before you provide personal information, you can contact us, and we will inform you based on the specific circumstances whether providing personal information is required by law or contract, or is necessary for entering into a contract, whether there is an obligation to provide personal information, and what the consequences will be if personal information is not provided.

13 Updates to the Privacy Policy

With the development of technology and revisions to laws, we may update this Privacy Policy from time to time and publish the updated privacy policy here.

Without your explicit consent, we will not reduce the rights you are entitled to under this policy. If you do not agree with the updated content, you can stop using the TecAlliance website and related services. If you continue to use our products or services, it means you agree to be bound by the revised privacy policy.

14 How to Contact Us

In accordance with the Measures for the Administration of Internet E-mail Services, the information contained on the TecAlliance website allows website users to conveniently contact the company and communicate directly with us. This includes so-called email. If you contact the processor via email or through a contact form, the personal information you transmit will be automatically stored. The voluntarily provided personal information to the processor will be stored for processing data subject requests or contacting you. This personal information will not be transferred to third parties.

If you have any questions, complaints, or suggestions regarding this Privacy Policy or personal information protection, you can contact us through any of the following methods:

Contact us at https://www.tecalliance.cn/cn/contact;

Send your questions to: sales_cn@tecalliance.net;

Mail to this address: Room 1015, Building 1, No. 1868 Gonghexin Road, Shanghai, China, 200072;

We will review the issues involved as soon as possible and respond within fifteen(15) days of receiving your complaint feedback.

You can revoke your consent to authorize the processing of personal information at any time. If you contact us via email, you can request the deletion of stored personal information at any time. In this case, subsequent communication between you and the personal information processor cannot continue.

Shanghai, China, April 9, 2024

TecAlliance China Ltd. (泰案联信息技术(上海)有限公司)