Prompt clause
Tinh Tinh Mall (hereinafter referred to as "we") will take corresponding security protection measures in accordance with the requirements of laws and regulations, and try its best to protect your personal information in a safe and controllable manner. In view of this, we have formulated this "Privacy Policy" (hereinafter referred to as "the Policy") and remind you:
This policy applies to Tinh Tinh Mall products and services, including Tinh Tinh Mall website (domain name is www.tinhtinh.com.kh) and Tinh Tinh Mall official account, Tinh Tinh Mall applet, Tinh Tinh Mall H5 page and client, Tinh Tinh Mall smart hardware and general Some functions/services of Tinh Tinh Mall are integrated as third-party services in Tinh Tinh Mall affiliates (see definition terms) and/or other third-party intelligent hardware, software or services. If the products or services provided by Tinh Tinh Mall are used in the products or services of our affiliated companies (see the definition section for details) but there is no independent privacy policy, this policy also applies to that part of the products or services.
What needs special explanation is, This privacy policy does not apply to services provided to you by other third parties through the aforementioned webpages or clients, mini programs or official accounts. For example, when you use third-party applications or services through Tinh Tinh Mall, or third-party services and products rely on Tinh Tinh Mall products to provide services to you, this policy does not apply to the information you provide to third parties.
Before using Tinh Tinh Mall products or services, please read carefully and thoroughly understand this policy, and use the relevant products or services after confirming your full understanding and consent. If you have any questions about this privacy policy, you can use our published contact information contact us. Once you start using Tinh Tinh Mall products or services, it means that you have fully understood and agreed to this policy, which means that you have agreed to our collection, processing, storage, use, sharing and protection of your personal information in accordance with this privacy policy.
Part one: Definition
Tinh Tinh Mall：Refers to the single or collective name of Cambodia Tinh Tinh Mall Enterprise Development Co., Ltd., which develops and provides Tinh Tinh Mall products and services, and related affiliated companies established now or in the future.
Tinh Tinh Mall Service: It refers to the SaaS products such as micro mall and advertising assistant developed and served by Tinh Tinh Mall. Help customers improve operational efficiency and profitability in the new retail era.
Affiliates: Refers to Cambodia Post E-Solutions plc. (www.cpes.com.kh)
Personal information: Refers to a variety of information recorded electronically or in other ways that can identify a specific natural person alone or in combination with other information or reflect the activities of a specific natural person.
Personal sensitive information: Refers to personal information including ID number, personal biometric information, bank account number, property information, whereabouts, transaction information, information about children under 14 years of age (including), etc. (We will consider specific personal sensitive information in this privacy policy Bold for prominent identification).
Personal information deletion: Refers to the act of removing personal information from the systems involved in the realization of daily business functions, Keep it in a state where it cannot be retrieved or accessed.
Unless otherwise agreed, the definitions used in this policy have the same meanings as those in the "Tinh Tinh Mall Registration Agreement".
Part Two: privacy policy
This privacy policy section will help you understand the following:
1、How we collect and use your information
2、How we use cookies and similar technologies
3、How we share, transfer, and publicly disclose your information
4、How we protect your information
5、How do you manage your information
6、How do we handle information about minors
7、How your information is transferred globally
8、How to update this privacy policy
9、How to contact us
1、How we collect and use your information
When you use our products and/or services, we need/may need to collect and use your personal information including the following two types:
1、In order to provide you with the basic functions of our products and/or services, you must authorize us to collect and use the necessary information. If you refuse to provide the corresponding information, you will not be able to use our products and/or services normally;
2、In order to provide you with additional functions of our products and/or services, you can choose to authorize us to collect and use information. If you refuse to provide, you will not be able to use the relevant additional functions or achieve the functional effects we intend to achieve, but it will not affect your normal use of the basic functions of our products and/or services. You understand and agree:
1、We are committed to creating a variety of products and services to meet your needs. Due to the many types of products and services we provide you, and the specific product/service scope that different users choose to use, the basic/additional functions and the type and scope of personal information collected and used will be different. Please follow The specific product/service function shall prevail;
2、In order to bring you a better product and service experience, we are constantly striving to improve our technology, and we may launch new or optimized functions from time to time, and may need to collect and use new personal information or change personal information Purpose or method of use. In this regard, we will separately explain to you the collection purpose, scope and use method of the corresponding information by updating this policy, pop-up windows, page prompts, etc., and provide you with a way to choose your consent, and after obtaining your express consent Collect and use. During this process, if you have any questions, comments or suggestions, you can contact us through various contact methods provided by Tinh Tinh Mall. We will answer you as soon as possible.
We will collect and use your personal information to realize the following functions of this policy:
（1）Provide account
In order to register an account to use our service, you need to provide your mobile phone number and password to create an account. If you only need to use browsing and search services, you do not need to register as our member and provide the above information.
For services that require a login account to use, we may verify your membership status based on the above information provided by you to ensure that we are providing services for you.
（2）Provide product or service information display
During your use of our services, in order to identify the abnormal status of your account, understand the suitability of the product, and provide you with page displays and search results that are more in line with your needs, We may automatically collect your usage and store it as web log information, Including: Device information: We will receive and record the device-related information you use (including device model, operating system version, device settings, unique device identifiers, device environment and other software and hardware characteristics information based on your specific operations during software installation and/or use. ), information about the location of the device (including your authorized GPS location and sensor information such as WLAN access points, Bluetooth, and base stations).
Service log information: When you use the products or services provided by our website or client, we will automatically collect your detailed usage of our services, Save as a service log, including browse, click to view, search query, favorite, add to shopping cart, transaction, after-sales, follow to share information, publish information, And the IP address, browser type, telecom operator, language used, date and time of visit.
Please note that separate device information and service log information are information that cannot identify specific natural persons. If we combine this type of non-personal information with other information to identify specific natural persons, Or use it in combination with personal information. During the combined use period, such non-personal information will be treated as personal information. Unless you have obtained your authorization or otherwise provided by laws and regulations, we will anonymize and remove such information. Identification processing.
In order to provide you with information display, search and push services that are more convenient and more in line with your individual needs, we will extract your preference characteristics based on your device information and service log information, and produce indirect crowd portraits based on the characteristic tags. Used to display, push information and possible commercial advertisements. If you do not want to accept the commercial advertisements sent to you by us, you can reply to unsubscribe through SMS prompts or unsubscribe or close by other means provided by us. When you use the on-site search service we provide, we also provide options that are not specific to your personal characteristics.
In addition, we will also use your above information in order to continuously improve and optimize the above functions.
（3）Help you complete order placement and order management
When you sell/order specific goods and/or services in our products and/or services, we will generate an order for you to purchase the goods and/or services through the system. During the ordering process, we will collect the consignee’s name, consignee address, and consignee’s contact phone number. At the same time, the order will contain the purchased goods and/or service information, the specific order number, the order creation time, and the amount to be paid. We collect this information to help you complete the transaction smoothly, protect your transaction security, query order information, provide customer service and after-sales service, and other purposes that we clearly inform.
You can order goods and/or services for other people, and you need to provide the aforementioned personal information of the actual orderer.
In order to facilitate you to understand and query order information and manage the order information, we will collect the order information generated during your use of our services to display it to you and facilitate your order management.
You can fill in/choose more additional information including other contact numbers and delivery time to ensure the accurate delivery of goods or services.
（4）Customer service and dispute handling
When you contact us or submit an application for after-sales and after-sales, dispute settlement, in order to protect your account and system security, we need you to provide the necessary personal information to verify your membership.
In order to contact you, help you solve the problem as soon as possible or record the solution and result of the related problem, We may save your communication/call records and related content with us (including account information, order information, other information you provide to prove relevant facts, or contact information you leave behind), If you make inquiries, complaints, or provide suggestions for specific orders, we will use your account information and order information.
In order to provide services and improve service quality for reasonable needs, we may also use other information about you, including relevant information you provide when you contact customer service, and questionnaire response information sent to us when you participate in a questionnaire survey.
（5）Provide you with security
In order to improve the security of your use of the services provided by us and our affiliates and partners, protect the personal and property safety of you, other users or the public, and better prevent phishing websites, fraud, network vulnerabilities, computer viruses, and network attacks , Network intrusion and other security risks, To more accurately identify violations of laws and regulations or related agreements and rules of Tinh Tinh Mall, We may use or integrate your account information, transaction information, device information, service log information, and information that our affiliates and partners have obtained your authorization or shared in accordance with the law, To comprehensively judge your account and transaction risks, conduct identity verification, detect and prevent security incidents, And take necessary record, audit, analysis, and disposal measures in accordance with the law.
（6）other
1、If the information you provide contains personal information of other users, you must ensure that you have obtained legal authorization before providing such personal information to Tinh Tinh Mall.
2、If we use information for other purposes not specified in this policy, or use information collected for specific purposes for other purposes, or we actively obtain your personal information from a third party, we will obtain your consent in advance . If we obtain your information indirectly from a third party, we will explicitly request the third party in writing to collect personal information after obtaining your consent in accordance with the law before collecting it. And inform you of the content of the shared information, and those involving sensitive information need to be clearly confirmed by you before being provided to us for use, and require a third party to make a commitment to the legality and compliance of the source of personal information, If a third party violates, we will explicitly require the other party to bear the corresponding legal responsibility; At the same time, our professional security team will strengthen the security of personal information (including sensitive information reporting, sensitive information encrypted storage, access control, etc.). We will protect the personal information obtained indirectly by using no less than the same protection methods and measures as our own users' personal information.
3、Exception with authorization
You fully understand and agree that we do not need your authorization or consent to collect and use your personal information under the following circumstances, and we may not respond to your requests for correction/modification, deletion, cancellation, withdrawal of consent, and information request:
（1）Related to national security and national defense security;
（2）Related to public safety, public health, and major public interests;
（3）Related to judicial or administrative law enforcement such as criminal investigation, prosecution, trial, and sentence execution;
（4）To protect your or other individuals’ life, property and other major legal rights, but it is difficult to obtain your consent;
（5）Your personal information disclosed to the public by yourself;
（6）Collect personal information from legally publicly disclosed information, such as legal news reports, government information disclosure and other channels;
（7）Necessary for signing and fulfilling relevant agreements or other written documents with you;
（8）Necessary for maintaining the safe and stable operation of the products and/or services provided, such as detecting and disposing of product and/or service failures;
（9）Necessary for legal news reporting;
（10）When it is necessary for academic research institutions to conduct statistical or academic research based on the public interest, and when they provide academic research or description results to the outside, they de-identify the personal information contained in the results;
（11）Other circumstances stipulated by laws and regulations.
Please be aware that, in accordance with applicable laws, if we take technical measures and other necessary measures to process personal information, the data recipient cannot re-identify specific individuals and cannot be restored, or we may conduct de-identification research on the collected information , Statistical analysis and prediction, used to improve the content and layout of Tinh Tinh Mall’s services, provide product or service support for business decisions, and improve our products and services (including the use of anonymous data for machine learning or model algorithm training). The use of processed data does not require separate notice to you and your consent.
4、If we stop operating Tinh Tinh Mall products or services, we will promptly stop continuing to collect your personal information, and will notify you of the suspension of operations in the form of one-by-one delivery or announcement, and we will also provide you with information about what we hold and the closed Business-related personal information is deleted or anonymized.
2、How we use cookies and similar technologies
（1）Cookie
In order to ensure the normal operation of the website, provide you with a more relaxed visit experience, and recommend you content that may be of interest to you, we will store cookies, Flash cookies, or browsers (or associated applications) on your computer or mobile device Others provided usually contain identifiers, site names, and some local storage of numbers and characters (collectively referred to as "Cookies"). With the help of cookies, websites can store data such as your preferences or the items in your shopping cart.
If allowed by your browser or browser additional services, you can modify your acceptance of cookies or reject our cookies. But if you do this, in some cases it may affect your safe access to our website, and you may need to change your user settings every time you visit our website.
（2）Cookie similar technology
In addition to cookies, we also use web beacons, pixel tags, ETags and other similar technologies on our website. For example, the email we send you may contain an address link that links to the content of our website. If you click the link, we will track the click to help us understand your product or service preferences so that we can actively improve our customers Service experience. A web beacon is usually a transparent image embedded in a website or email. With the help of the pixel tag in the email, we can know whether the email has been opened. If you do not want your activities to be tracked in this way, you can unsubscribe from our mailing list at any time.
ETag (Entity Tag) is the HTTP protocol header transmitted between the Internet browser and the Internet server and can replace Cookie. ETag can help us avoid unnecessary server load, improve service efficiency, and save resources and energy. At the same time, we may use ETag to record your identity so that we can understand and improve our products or services more deeply. Most browsers provide users with the function of clearing the browser cache data. You can perform the corresponding data clearing operation in the browser settings function. However, please note that if you disable ETag, you may not be able to enjoy a relatively better product or service experience.
3、How we share, transfer, and publicly disclose your information
（1）shared
We will not share your personal information with companies, organizations and individuals other than Tinh Tinh Mall service providers, except in the following cases:
1、Sharing under statutory circumstances: We may share your personal information with external parties in accordance with laws and regulations, litigation, dispute resolution needs, or requirements of administrative and judicial organs in accordance with the law.
2、Sharing with explicit consent: After obtaining your explicit consent, we will share your personal information with other parties.
3、Sharing in the case of your active choice: You purchase goods or services through Tinh Tinh Mall, and we will share the necessary information related to the transaction in your order information to the providers of related goods or services according to your choice to achieve your Transaction and after-sales service needs.
4、Sharing with affiliated companies: In order to facilitate us to provide you with products and services based on the Tinh Tinh Mall account, recommend information that may be of interest to you, identify abnormal member accounts, and protect the personal and property safety of Tinh Tinh Mall affiliates or other users or the public from infringement , Your personal information may be shared with our affiliates and/or their designated service providers. We will only share necessary personal information and are bound by the purpose stated in this privacy policy. If we share your sensitive personal information or the associated company changes the purpose of using and processing personal information, we will again seek your authorization and consent.
5、Share with authorized partners: We may entrust authorized partners to provide you with certain services or perform functions on our behalf. We will only share your information for legal, legitimate, necessary, specific and clear purposes stated in this privacy policy. Authorized partners can only Access to the information needed to perform their duties, and shall not use this information for any other purpose. Currently, our authorized partners include the following types:
（1）Authorized partners for advertising and analysis services. Unless we have your permission, we will not share your personal identification information with partners that provide advertising and analysis services. We will entrust these partners to process information related to the coverage and effectiveness of advertising, but will not provide your personally identifiable information, or we will de-identify this information so that it will not identify you personally. Such partners may combine the above-mentioned information with other data they obtain legally to implement advertising services or decision-making suggestions entrusted by us.
（2）Suppliers, service providers and other partners. We send information to suppliers, service providers, and other partners that support our business. These supports include technical infrastructure services commissioned by us, analysis of how our services are used, measuring the effectiveness of advertising and services, and providing customers Services, payment facilitation or conducting academic research and surveys. We will conduct strict security inspections on the application program interface (API) and software tool development kit (SDK) for authorized partners to obtain relevant information, and agree on strict data protection measures with authorized partners, so that they can comply with our entrusted purpose, Service description, this privacy policy and any other relevant confidentiality and security measures to handle personal information.
（2）transfer
We will not transfer your personal information to any company, organization or individual, except in the following cases:
1、Transfer with explicit consent: After obtaining your explicit consent, we will transfer your personal information to other parties;
2、In the event of merger, acquisition or bankruptcy liquidation of Tinh Tinh Mall service providers, or other situations involving mergers, acquisitions or bankruptcy liquidation, if the transfer of personal information is involved, we will require new companies and organizations that hold your personal information to continue to receive Restricted by this policy, otherwise we will require the company, organization and individual to seek authorization and consent from you again.
（3）Public disclosure
We will only publicly disclose your personal information under the following circumstances:
1、With your explicit consent or based on your active choice, we may publicly disclose your personal information;
2、If we determine that you have violated laws and regulations or seriously violated the relevant agreements and rules of Tinh Tinh Mall, or to protect the personal and property safety of Weimob users or the public from infringement, we may disclose in accordance with laws and regulations or with your consent Regarding your personal information, including relevant violations and the measures Tinh Tinh Mall platform has taken against you.
（4）Exceptions for obtaining prior authorization and consent when sharing, transferring, and publicly disclosing personal information
In the following situations, sharing, transferring, and publicly disclosing your personal information does not require your prior authorization:
1、Related to national security and national defense security;
2、Related to public safety, public health, and major public interests;
3、Related to judicial or administrative law enforcement such as criminal investigation, prosecution, trial, and sentence execution;
4、To protect your or other individuals’ life, property and other major legal rights, but it is difficult to obtain your consent;
5、Your personal information disclosed to the public by yourself;
6、Collect personal information from legally publicly disclosed information, such as legal news reports, government information disclosure and other channels. Please be aware that, according to applicable laws, if we take technical measures and other necessary measures to process personal information so that the data recipient cannot re-identify specific individuals and cannot be restored, there is no need to share, transfer, and publicly disclose such processed data. We will notify you separately and get your consent.
4、How we protect your information
（1）We have adopted reasonable and feasible security protection measures that comply with industry standards to protect your information and prevent unauthorized access, public disclosure, use, modification, damage or loss of personal information. For example, the data exchange between your browser and the server is protected by SSL protocol encryption; We also provide the HTTPS protocol for secure browsing on the Dingding Mall website; we will use encryption technology to improve the security of personal information; we will use trusted protection mechanisms to prevent malicious attacks on personal information; We will deploy an access control mechanism to ensure that only authorized personnel can access personal information; And we will organize security and privacy protection training courses to strengthen employees' awareness of the importance of protecting personal information.
（2）We have an industry-leading data security management system with data as the core and around the data life cycle. We improve the security of the entire system in multiple dimensions from organizational construction, system design, personnel management, and product technology. At present, our important information systems have passed the three-level or higher evaluation of network security protection.
（3）We will take reasonable and feasible measures and try our best to avoid collecting irrelevant personal information. We will only retain your personal information for the period required to achieve the purpose stated in the policy, unless there is a mandatory retention requirement by law.
After your personal information exceeds the retention period, we will delete your personal information or make it anonymized in accordance with the requirements of applicable laws.
（4）The Internet is not an absolutely safe environment. When using Tinh Tinh Mall services, we strongly recommend that you do not use communication methods not recommended by Tinh Tinh Mall to send your information. You can establish contact and share with each other through our services. When you create a communication, transaction, or sharing through our services, you can independently choose the object of communication, transaction or sharing, as a third party who can see your transaction content, contact information, exchange information or sharing content and other related information.
When using the Tinh Tinh Mall service for online transactions, you will inevitably disclose your personal information, such as contact information or contact address, to the counterparty or potential counterparty. Please properly protect your personal information and only provide it to others when necessary. If you find that your personal information, especially your account or password, has been leaked, please contact Tinh Tinh Mall customer service immediately so that we can take corresponding measures according to your application.
Please note that the information you voluntarily share or even publicly share when using our services may involve personal information or even personal sensitive information of you or others. Please be more cautious about whether to share or even publicly share relevant information when using our services.
Please use a complex password to help us ensure the security of your account. We will do our best to ensure the security of any information you send to us. If our physical, technical or management protection facilities are damaged, resulting in unauthorized access, public disclosure, tampering or destruction of information, and damage to your legitimate rights and interests, we will bear the corresponding legal responsibility.
（5）In the unfortunate event of a personal information security incident, we will inform you in accordance with the requirements of laws and regulations: the basic situation and possible impact of the security incident, the disposal measures we have taken or will take, suggestions that you can independently prevent and reduce risks, Remedies for you, etc. We will inform you of the incident-related situation by email, letter, telephone, push notification, etc. When it is difficult to inform the subject of personal information one by one, we will adopt a reasonable and effective way to publish an announcement.
At the same time, we will also report the handling of personal information security incidents in accordance with the requirements of the regulatory authorities. At the same time, we will also report the handling of personal information security incidents in accordance with the requirements of the regulatory authorities.
5、How do you manage your information
You have the following rights with respect to your personal information:
（1）You have the right to access your personal information, except for exceptions provided by laws and regulations. If you want to exercise the right of data access, you can do so by yourself:
account information ——If you wish to access or edit the personal information and payment information in your account, change your password, add security information or close your account, you can perform such operations by visiting the Tinh Tinh Mall website.
Search Information ——You can access or clear your search history, view and modify interests, and manage other data in Tinh Tinh Mall and related websites.
If you cannot access this personal information through the above links, you can contact our customer service at any time. We will respond to your request for access within 30 days.
（2）You have the right to correct your personal information;
（3）You have the right to delete your personal information. You can log in to the Tinh Tinh Mall account, click on the account you need to cancel, and then when you confirm to delete your account information, we will delete your information, and the resulting rights or assets will disappear at the same time The loss shall be borne by you;
（4）You have the right to change the scope of your authorization.
You can access and update the above information through the homepage of Tinh Tinh Mall website.
If you believe that Tinh Tinh Mall has collected and used your personal information in violation of the law, you can contact us through Tinnh Tinh Mall customer service.
6、How do we handle information about minors
In e-commerce activities, we presume that you have the corresponding civil capacity. If you are a minor, we ask you to ask your parents or guardians to read this privacy policy carefully and use our services or provide us with information with the consent of your parents or guardians.
In the case of collecting personal information of minors by using our products or services with the consent of their parents or guardians, we will only use, share, or transfer them when permitted by laws and regulations, the parents or guardians have expressly agreed, or are necessary to protect minors Or disclose this information.
7、How your information is transferred globally
The personal information collected and generated during our operations in the People's Republic of China is stored in China, except in the following circumstances:
1、The applicable law has clear regulations;
2、Obtain your explicit authorization;
3、You conduct personal active actions such as cross-border transactions through the Internet.
In response to the above circumstances, we will ensure that your personal information is adequately protected in accordance with this privacy policy.
8、How to update this privacy policy
Our privacy policy may change.
Without your explicit consent, we will not restrict your rights in accordance with this privacy policy. We will post any changes to the privacy policy on a dedicated page.
For major changes, we will also provide more noticeable notifications (including we will notify you through the Tinh Tinh Mall website and even provide you with pop-up prompts).
The major changes referred to in this policy include but are not limited to:
1、Our service model has undergone major changes. Such as the purpose of processing personal information, the type of personal information processed, the way of using personal information, etc.;
2、Significant changes have taken place in our control and other aspects. Such as changes in the information controller caused by mergers and acquisitions, etc.;
3、Changes in the main objects of personal information sharing, transfer or public disclosure;
4、Your right to participate in the processing of personal information and how to exercise it has undergone major changes;
5、Changes in our responsible department, contact information and complaint channels for handling personal information security;
6、The personal information security impact assessment report shows that there is a high risk.
We will also archive the old version of this privacy policy on a special page of the Dingding Mall website for your review.
9、How to contact us
We have set up a personal information protection department. If you have any questions, comments or suggestions about the content of this policy, or find that your personal information may be leaked, you can contact us at cambodiapostesolutions@cpes.com.kh, and we will reply to you within 15 days Request.
If you are not satisfied with our response, especially if you believe that our personal information processing has harmed your legal rights, you can also seek a solution by filing a lawsuit with the court with jurisdiction in the defendant's domicile.