DAM Privacy Policy

Version date: 2023/10/9

Introduction

Tezign (Shanghai) Information And Technology Co.,Ltd (hereinafter referred to as "we" or "Tezign") is committed to protecting the personal information of our users. In accordance with the Network Security Law of the People's Republic of China (hereinafter referred to as "Network Security Law"), the Personal Information Protection Law, GB/T35273 "Information Technology Security Personal Information Security Specification" and other related laws and regulations, we have formulated the "Privacy Policy of Tezign Digital Asset Management System" (hereinafter referred to as "This Privacy Policy" or "DAM Privacy Policy") to explain to you how we will collect, use, share, transfer, and disclose such information when you use our products and or services, and the ways we provide you with access to, update, delete, and protect this information. We are committed to maintaining your trust in us and to protecting your personal information by adhering to the following principles: the principles of uniformity of rights and responsibilities, clarity of purpose, choice of consent, minimum necessary, ensuring security, subject involvement, and openness and transparency.

It should be especially noted that this privacy policy only applies to the products and or services provided by Tezign Digital Asset Management System for you, and does not apply to the products and or services provided to you by other third parties, whose services provided to you are subject to their terms of service and privacy policy separately stated to you (instead of this privacy policy). Please protect your personal information and provide it to third parties only when necessary.

This policy will help you understand the following.

• How we collect and use your personal information

• How we use cookies and similar technologies

• How we share, transfer, and publicly disclose your personal information

• How we protect and store your personal information

• How you manage your personal information

• How we handle information from minors

• How to update this privacy policy

• How to contact us

This Privacy Policy relates to the DAM product you are using and the various business features included in that product, and we hope you will read it carefully before you visit and confirm that you have fully understood what is written in this Privacy Policy and that it allows you to make the choices you deem appropriate in accordance with the guidelines in this Privacy Policy. By using or continuing to use our products and or services after we have updated this Privacy Policy (and we will promptly notify you of such updates), you agree to the contents of this Privacy Policy (including the updated version) and consent to our collection, use, storage and sharing of your relevant information in accordance with this Privacy Policy.

If you have any questions about this Privacy Policy or related matters, you may contact us using the contact information in Section 8 of this Privacy Policy. If you do not accept the terms of this Privacy Policy, please stop accessing our DAM products and or services immediately.

I. How we collect and use your personal information

Personal information refers to all kinds of information recorded electronically or otherwise that can identify a specific natural person or reflect the activities of a specific natural person, either alone or in combination with other information.

The personal information covered by this privacy policy includes:

• Basic information: name, personal phone number, e-mail, Company information;

• Internet identification information: Personal Information Subject Account (ID, nickname, avatar), IP address;

• Personal Internet access records: including browsing records, product usage records, click records;

• Personal common device information: device model, operating system version.

Sensitive personal information is personal information that may endanger personal and property safety if leaked, illegally provided or misused, and is highly likely to lead to damage to personal reputation, physical and mental health or discriminatory treatment, etc. It includes personal information such as identity document number, personal biometric information, bank account number, property information, whereabouts, transaction information, information of children under 14 years old (inclusive), etc.

This privacy policy covers personally sensitive information including:

• Web Browsing History

We will only collect and use your personal information for the following purposes:

(i) When you must authorize us to collect and use your personal information

1. If you do not provide relevant information, you will not be able to become our registered user and enjoy our core features. This relevant information includes:

Collecting scenes	Types of personal information	Purpose of use
User registration / login	Name, email, mobile phone number	Login, collaboration, internal sharing, business callbacks
	Name, mobile phone number, email address, department information	Feishu Authorized Login
	WeChat avatar, nickname, gender, UnionID	WeChat Authorized Login
	Name, mobile phone number, email, userID, department information	Dingding Authorized Login
	WeChat avatar, name, gender, department information, UnionID	Enterprise WeChat Authorized Login
	Contact name, mobile phone number, email	Add external contacts, corporate members
Material Sharing - Users on the Internet (not logged in)	IP address	Traceability Sharing Path
Content Hub	WeChat avatar, nickname, Web Browsing History	Statistics and analysis of data

2. We collect the following information in the course of your use of the Services.

• Device Information: We will receive and record information about the attributes of the device you are using (e.g., device model, operating system version), and information about the location of the device, based on the specific permissions you grant in the installation and use of the Software. We may correlate the first two types of information so that we can provide you with consistent service across devices.
• Log information: When you use our website or services provided by our client, we will automatically collect details of your use of our services (including website browsing records, product usage records, click records, etc.) and keep them as relevant web logs. For example, log records of file size or type, sharing links, sharing links being opened or downloaded by others, application or function crashes, and other behaviors.
• User account support information: Based on your use of the Services, we will record and analyze your inquiry logs and troubleshooting processes for users in order to respond to your requests for assistance in a timely manner and to improve the Services. Please note that separate device information, log information, and support information is not information that can identify a specific natural person.

When we provide business functions or specific services to you, we will collect, use, store, provide and protect your information in accordance with this Privacy Policy and the corresponding User Agreement, if we collect information from you beyond the scope of this Privacy Policy and the corresponding User Agreement, we will separately explain to you the scope and purpose of information collection and obtain your consent before collecting the personal information necessary to provide the corresponding services.

3. If a user uploads a file containing personal information, the user promises to keep the collected personal information strictly confidential, to use it only for the purpose for which it was collected, and to delete it after use. If the user uses the information arbitrarily without the express consent of the right holder of the personal information, the user shall bear the corresponding legal responsibility to the right holder of the personal information by himself or herself.

(ii)You are fully aware that in accordance with laws, regulations and national standards, we may collect and use personal information without your authorized consent in the following circumstances:

• related to the fulfillment of our obligations under laws and regulations;
• directly related to national security or national defense security;
• directly related to public safety, public health, or significant public interest;
• directly related to criminal investigation, prosecution, trial and execution of judgments, etc.;
• for the protection of your or other individuals' life, property and other significant legitimate rights and interests, but it is difficult to obtain their consent;
• where the personal information collected is disclosed by you to the public at your own discretion;
• necessary for the conclusion and performance of a contract at your request;
• where personal information is collected from lawfully publicly disclosed information, such as lawful news reports, government information disclosure and other channels;
• necessary to maintain the safe and stable operation of the products and/or services provided, such as the detection and disposal of product and/or service failures;
• necessary for carrying out legitimate news reporting;
• necessary for academic research institutions to conduct statistical or academic research in the public interest and to de-identify the personal information contained in the results when providing the results of academic research or descriptions to the public;
• other circumstances specified by laws and regulations.

(iii) Rules for the use of your personal information

• We will use the personal information we collect in accordance with this Privacy Policy and for the purpose of implementing the functionality of our products or services.
• After collecting your personal information, we will import your information into our backend database through technical means. We have the right to store and analyze the user database and use it for non-commercial purposes.
• Please note that all personal information you provide when using our products or services will be continuously licensed to us for the duration of your use of our products or services, unless you delete it or refuse to allow us to collect it through system settings.
• When we want to use your personal information for other purposes not stated in this policy, or use the information collected for specific purposes for other purposes, we will inform you in advance and ask for your consent in advance.

II. How we use cookies

• Use of Cookies

  To ensure that the Site works properly, to make your visit experience easier, and to recommend content that may be of interest to you, we may store on your computer or mobile device a local storage called a cookie, Flash cookie, or other local storage provided by your browser or associated application that typically contains an identifier, site name, and some numbers and characters (collectively "Cookies"). With the help of Cookies, the Site is able to store your preferences or data. We do not use Cookies for any purpose other than those described in this Privacy Policy. You can manage or delete Cookies according to your preferences. you can clear all Cookies saved on your computer, and most web browsers automatically accept Cookies, but you can usually modify your browser's settings to reject Cookies if you wish; alternatively, you can clear all Cookies that have been saved, but if you do so, you If you do so, you may need to personally change your user settings each time you visit the site, and any corresponding information you have previously recorded will be deleted.

III. How we share, transfer and publicly disclose your personal information

(i) Sharing

We will not share your personal information with companies, organizations and individuals outside of us and our affiliates, except for the following.

• Sharing with your express consent or authorization, including your consent or authorization based on this Privacy Policy and your consent or authorization in other agreements or rules of Tezign.
• Sharing under Statutory Circumstances, Provided when required by applicable law or regulation, legal process, or mandatory administrative or judicial requirements.
• Sharing with Affiliates, We may share your personal information with our affiliates. (An affiliate is one party that controls or exercises significant influence over another party, and two or more parties that are under common control, joint control or significant influence constitute affiliates.) However, we will only share personal information that is necessary and subject to the purposes stated in this Privacy Policy. If our affiliated parties wish to change the purposes for which personal information is processed, they will again seek your authorized consent.
• Sharing with counterparties for transaction purposes, We will share your information in accordance with the agreement between you and the counterparty for transaction purposes.
• Sharing at your request, Sharing at your request for you to handle disputes or controversies between you and others.
• Sharing with partners such as suppliers, service providers: We may engage partners to provide certain services to you or to perform functions on our behalf. The services provided by our partners include: (a) cell phone number verification; (b) marketing and customer acquisition; (c) statistics and analysis of data; and (d) technical support. Before doing so, we will agree with them the rights and obligations of both parties in a manner that is not limited to signing an agreement. We will only process your information for lawful, legitimate, necessary, specific and explicit purposes and partners will only have access to the information they need to perform their duties and will not use this information for any other purpose.
• Necessary data sharing with third parties based on application program interfaces (APIs), software tool development kits (SDKs), which may vary from version to version (generally including third-party account login category, sharing category, third-party payment category, vendor push category, statistics category, etc.). For information on how third parties collect and use your personal information, it is recommended to refer to the relevant service We recommend that you refer to the relevant service agreements and personal information protection statements of the third party SDKs, as follows:

No.	SDK Name	Affiliated Companies	Types	Purpose	Privacy Policy Link
1	WeChat	Tencent	WeChat avatar, nickname, region, gender, unionID	Login	https://open.weixin.qq.com/cgi-bin/frame?t=news/protocol_developer_tmpl
2	Enterprise WeChat	Tencent	WeChat avatar, name, region, genderunionID, department information	Login	https://gov.weixin.qq.com/privacy
3	Feishu	ByteDance	Name, mobile phone number, email, department information, userID	Login	https://www.feishu.cn/zh_cn/privacy?lang=zh
4	Dingding	Alibaba	Name, mobile phone number, email, userID, department information	Login	https://terms.alicdn.com/legal-agreement/terms/suit_bu1_dingtalk/suit_bu1_dingtalk202010070946_49604.html
5	AzureAD	Microsoft	Name, mobile phone number, email, userID, department information	Login	https://privacy.microsoft.com/zh-cn/privacystatement

(ii) Transfer

We will not transfer your personal information to any company, organization or individual, except for the following.

• Where the transfer is made with the acquisition of express consent, after obtaining your express consent, we will transfer your personal information to other parties.
• In the event of a merger, acquisition, transfer of assets or similar transaction involving us that involves the transfer of personal information, we will require the new company or organization holding your personal information to continue to be bound by this Privacy Policy, or we will require that company or organization to seek your authorized consent again.
• Provided in accordance with applicable laws and regulations, the requirements of legal proceedings, mandatory administrative or judicial requirements necessary to do so.

(iii) Public disclosure

We will only publicly disclose your personal information if we have taken industry-standard safety precautions to:

• with your express consent, to disclose the personal information you have specified.
• if we are required to provide your personal information by law, regulation, mandatory administrative enforcement or judicial request, we may publicly disclose your personal information based on the type of personal information requested and the manner of disclosure. When we receive such a request for disclosure of information, we will require that a legal document, such as a subpoena or letter of inquiry, must be issued in accordance with the law or regulation. All requests are carefully reviewed to ensure that they have a lawful basis and are limited to data that law enforcement authorities have a legitimate right to obtain for specific investigative purposes.

IV. How we protect and store your personal information

(i) Our technology and measures to protect your personal information

• We have obtained ISO27001&27017 Information Security Management System Certification, which is a widely adopted global security standard. This certification fully proves that Tezign's product security management meets internationally recognized standards and can provide users with a systematic and continuous method to manage information security in order to protect the privacy, integrity and availability of their own and customers' data information. privacy, integrity and availability of their own and customers' data information.
• We have obtained the certificate of Information System Security Level Protection (Level 3) and passed the certification of "Level 3", which indicates that the information security management capability of DAM products of Tezign has reached the domestic standard, and the main capability is to protect the system from malicious attacks and other threats of considerable harm launched by external organized groups under the unified security policy. It is able to detect security loopholes and security incidents, and restore most of the functions quickly after the system is damaged. In the event of a security incident, Tezign has sufficient response capability to quickly restore functions and thus protect the information security of users.
• We will strive to adopt security measures that meet industry standards, including the establishment of reasonable system specifications, security technology, and regular security vulnerability scanning to prevent unauthorized access, use, and modification of your personal information and avoid damage or loss of data.
• We will retain your personal information only for as long as necessary to achieve the purposes described in this Privacy Policy. We also organize information security training courses to enhance employees' awareness of the importance of protecting personal information.
• We only allow access to personal information to our employees and those of our affiliates who have a need to know that information, and we have strict access controls and monitoring mechanisms in place to do so. We also require all persons who may come into contact with your personal information to comply with the corresponding confidentiality obligations. Failure to comply with these obligations may result in legal liability.
• The Internet is not an absolutely secure environment, and it is not possible to determine whether email, instant messaging, social networking software, and other means of communication with other users are fully encrypted. We recommend that you use complex passwords when using such tools, and take care to protect the security of your personal information.
• When trading products and/or services with third parties through the website, you may need to disclose your personal information, such as contact information or email address, to the counterparty or potential counterparty. Please protect your personal information and provide it to others only when necessary.
• After the unfortunate occurrence of a personal information security incident, we will promptly inform you, in accordance with the requirements of laws and regulations, of the basic situation and possible impact of the security incident, the measures we have taken or will take to deal with it, the suggestions you can independently prevent and reduce the risk, and the remedial measures for you. We will also promptly inform you of the event-related situation by email, letter, telephone, SMS notification, and when it is difficult to inform the subject of personal information one by one, we will take reasonable and effective ways to issue announcements. At the same time, we will also take the initiative to report the disposition of personal information security incidents in accordance with the requirements of regulatory authorities.
• If you have any questions about our personal information protection, you can contact us through the contact information agreed at the bottom of this privacy policy. If you find that your personal information has been compromised, especially your account number, please contact us immediately through the contact information agreed in Article 8 "How to Contact Us" of this Privacy Policy so that we can take appropriate measures.

(ii) Storage of your personal information

• Personal information collected and generated by us in our operations in the People's Republic of China is stored in China. In the event of cross-border transfer of data, we will separately inform you by push notification, pop-up window or email of the purpose of data exit, recipient, etc., and obtain your authorized consent, and we will ensure that the data recipient has sufficient data protection capacity to protect your personal information. We promise that your personal information will always be stored for the period reasonably necessary. If it is necessary to transmit information data outside of China for business purposes, you shall conduct an outbound security assessment of personal information in accordance with the recognized professional standards of the industry and applicable laws and regulations. You shall ensure that you have obtained the individual consent of the data subject in accordance with the applicable laws and regulations and complete the pre-requisite procedures for cross-border transmission in accordance with the laws and regulations of the place where the data is sent and the place where the data is received, including, but not limited to, the declaration and approval to the governmental agencies.
• If we terminate our services or operations, we will notify you at least thirty days in advance and delete or anonymize your personal information after the termination of services or operations, except for the following cases,(1) Complying with the requirements of laws and regulations regarding information retention (e.g., the Network Security Law requires that technical measures be taken to monitor and record network operation status and network security events, and that relevant network logs be retained for not less than six months in accordance with the regulations);(2) Reasonable extension of the period is required for financial, audit, dispute resolution and other purposes.

V. How you manage your personal information

Tezign takes your concerns about your personal information seriously and makes every effort to protect your rights to access, correct, delete and withdraw consent to your personal information so that you have the full ability to safeguard your privacy and security.

• Access and correction of your personal information.
  You have the right to request access to your personal information, subject to the exceptions provided by law or regulation. When you discover errors in the information we process about you, you have the right to correct inaccurate or incomplete information. You can independently inquire or update your personal information under your account, modify your avatar, name, department, position, etc. by clicking [Avatar - Account Information Settings], and you can also unbind your third party account through the above path.
• Delete your personal information. You can request us to delete your personal information in the following cases,
  (1) If our handling of personal information violates laws and regulations;
  (2) If we collect and use your personal information without your consent;
  (3) If we handle personal information in violation of the agreement with you;
  (4) If we terminate our services and operations.
• Cancellation. You can send us a request to cancel your account through the contact information in Article 8 of this Privacy Policy, and you can also complete the transfer of account rights or cancel your account within the DAM system according to your needs. You are solely responsible for your actions prior to and during your use of the DAM service. You can transfer or backup the information and data in your account before you cancel, and after you cancel successfully, you will not be able to login or perform any operation through your original account. Please note that it is impossible to recover your account after logging out, so please use the logout function carefully.
• Responding to your requests. If you are unable to access, correct or delete your personal information by the above means, or if you need to access, correct or delete other personal information generated by your use of our products and/or services, or if you believe that there is any violation of laws and regulations or any agreement with you regarding the collection or use of personal information, you may contact us by sending an email. We will reply within 48 hours after receiving your feedback and process your request within 15 days.
• In the following cases, we will not be able to respond to your request in accordance with the requirements of laws and regulations,
  (1) Related to national security and national defense security;
  (2) Related to public safety, public health, and significant public interests;
  (3) Related to criminal investigation, prosecution, trial and execution of judgments, etc;
  (4) Where there is sufficient evidence that you have subjective malice or abuse of rights;
  (5) Responding to your request will lead to serious damage to the legitimate rights and interests of you or other individuals or organizations;
  (6) Where commercial secrets are involved;
  (7) Where it is relevant to the performance of our obligations under laws and regulations;
  (8) For the purpose of safeguarding your or other individuals' life, property and other significant legitimate rights and interests but it is difficult to obtain my consent.

VI. Protection of personal information of minors

• Tezign attaches great importance to the protection of personal information of minors, and we presume that you have the appropriate civil capacity when using our products and/or services. If you are a minor under the age of 18, you should obtain prior written consent from your parent or legal guardian before using our products and/or services. Tezign protects the personal information of minors in accordance with the provisions of relevant national laws and regulations.
• In the case of personal information collected from a minor with the consent of a parent or legal guardian, we will only use share, transfer or disclose this information as permitted by law, with the express consent of the parent or guardian, or as necessary to protect the minor.
• If we discover that a minor has registered to use our products or services without the actual consent of a parent or legal guardian, we will temporarily freeze the account and will not be able to use our products and/or services at that time, and we will attempt to contact the guardian and try to delete the minor's personal information as soon as possible.

VII. How to update this policy

• This Privacy Policy will be updated to provide you with better service and as Tezign DAM's business evolves. However, we will not reduce your rights under this Privacy Policy without your express consent. We will notify you of any updates to this Privacy Policy by posting an updated version on our website and by posting a notice on our website or by other appropriate means before it becomes effective, and we ask that you visit DAM products to keep up to date with the latest Privacy Policy. If you agree to accept the updated Privacy Policy by clicking or checking the box, or if you continue to use our products or services, you agree to accept the contents of this Privacy Policy as amended.
• For major changes, we will also provide more prominent notification (we will make a special notice on the viewing page, etc.).
• Material changes within the meaning of this Privacy Policy include, but are not limited to(1) a material change in our business model. such as the purposes for which personal information is processed, the types of personal information processed, how personal information is used; the addition or iteration of our service offerings. (2) We undergo significant changes in our corporate ownership structure, organizational structure. such as business restructuring, change of ownership due to bankruptcy and merger. (3) A change in the primary recipients of personal information sharing, transfer or public disclosure. (4) Significant changes in your rights to participate in the processing of personal information and how they are exercised. (5) When there is a change in our contact information responsible for handling personal information security. (6) When the personal information security impact assessment report indicates that there is a high risk.
• This Privacy Policy is published in English and Chinese. If there is any inconsistence or conflict between the two versions, the Chinese version shall prevail.

VIII. How to contact us

If you have any questions, comments or suggestions about this Privacy Policy or matters related to your personal information, please feel free to contact us.

Our email address is support@tezign.com

Contact address is 21F,175 Longyao Road, Xuhui District, Shanghai

Upon receipt of your feedback, we will respond in a timely manner and give treatment within a reasonable time frame in accordance with laws and regulations and the provisions of this Privacy Policy.