TINAVAT Privacy and Cookie Policy

Effective 1 August 2016

TINAVAT is committed to protecting its visitors' and users' privacy, confidentiality and security of the personal information we hold by complying with the requirements of Personal Data (Privacy) Ordinance (“Ordinance”) with respect to the management of personal information. The following Privacy and Cookie Policy outlines the information TMTM Ltd. (hereafter “TINAVAT”, “we”, or “us”) may process and how we may use that information to better serve visitors and users while using our Site www.TINAVAT.com (the “Site”) and our on-demand services (collectively the “Service). Please review the following carefully so that you understand our privacy practices.

1. General

1.1 By using the Services in any manner, including but not limited to visiting or browsing the Site, you (the “user” or “ you”) agree to be bound by this Privacy and Cookie Policy, including those additional terms and conditions and policies referenced herein and/or available by hyperlink. This Privacy and Cookie Policy applies to all users of the Services, including and without limitation to the users who are vendors, customers, merchants, contributors of content, information and other materials or services on the Site.

1.2 By registering to the Site you expressly consent to

1.3 For the purposes of processing payments of the Services of your choice, processing, managing or storing your personal information for providing better experience to you when using our Services, we may transfer your personal information such as your contact details outside Hong Kong to our relevant agents (such as the companies mentioned herein) situated in European Union or U.S.A. or elsewhere, where there may not be in place data protection laws which are substantially similar to, or serve the same purposes as the Personal Data (Privacy) Ordinance. That means your personal data may not be protected to the same or similar level as in Hong Kong.

1.4 By accepting this Privacy and Cookie Policy you accept that TINAVAT may provide the following personal data stored in its user database to OTP Mobile Ltd., to Paysera LT or any other third party needed to perform the Service related liabilities: username, email address, phone number, physical address, preferred language. The purpose of data transmission: customer support for users, confirming transactions and fraud-monitoring for users defense.

2. Information Collected or Received

2.1 Personal information you give us when you use our Services

TINAVAT requires a user to provide a valid email address and choose a username connected with your site activity through an encrypted password.

2.2 Depending on the services you choose, you may provide TINAVAT information such as your real name, tax number, other identification number, physical address, phone number, Skype ID, website, blog, date of birth / foundation, other proof of identification.

2.3 TINAVAT may contact you to confidentially request more information about listings or items listed on the Site, to ensure compliance with our rules. Certain products or services on TINAVAT may require you to complete an application; any information you submit through the application processes will not be displayed publicly and will only be used internally by TINAVAT, unless otherwise specified.

2.4 You may optionally choose to provide your full name and other personal information (such as birthday, gender, location, marital status, working experience, education, interests, hobbies) to be publicly displayed.

2.5 You may connect to TINAVAT with an external application, in which case TINAVAT may receive some information from that other service.

2.6 We may use cookies, clear gifs, log files, and flash cookies for several purposes, including to help understand how people interact with our Site and Services and to improve the usability of the Site and Services in order to provide a better experience to users.

2.7 Your username, TINAVAT ID or alias is publicly displayed and connected to your TINAVAT activity. Other people may see your date joined, reviews, ratings, profile information, listing pages, completed listings, and comments in community spaces.

2.8 TINAVAT automatically receives and records some information from your browser or your mobile device when you visit the Site, such as your IP address or unique device identifier, cookies and data about which pages you visit on the Site. This information helps us analyze and understand how the Site works for users and visitors, and provide a more personalized experience for users and visitors. Such information may be handed over to a third party (such as Google Analytics), which owes a duty of confidentiality to us, for data processing and management.

2.9 Some users or visitors may connect to or register a TINAVAT account using an external third-party application. TINAVAT may receive some data from those connected third-party applications. Connecting your TINAVAT account to third-party applications or services is optional, and when you connect your account to an external app, you will be given the opportunity to grant permission.

2.10 We may allow you to share information with third party social media sites, or use social media sites or other sites to create or connect to your account. Those social media sites may give us access to certain personal information stored by them (e.g., content viewed and information about the advertisements within the content you have been shown or may have clicked on, etc.) from your interaction with these online services. This Privacy and Cookies Policy does not apply to these third party sites and we have no control over the information that you submit to those third parties. You should read the relevant privacy policy for those third party sites before responding to any offers, products or services advertised by these parties.

2.11 TINAVAT may receive or collect information (for example: an email address) about a person who is not yet a registered TINAVAT user (a “non-member”) in connection with certain TINAVAT features, including but not limited to: a non-member subscribing to a TINAVAT newsletter, a user inviting a non-member to visit the Site and/or a non-member engaging in a transaction. Non-member information is used only for the purpose it was originally submitted to TINAVAT. A non-member can contact our Customer service if they do not want TINAVAT to retain their information.

2.12 You may also provide us with other information through your participation in community discussions, chats, dispute resolution, correspondence through our sites, or correspondence sent to us.

2.13 We will also receive your information through you participating in bidding, buying, or selling in a particular transaction or other transactions based on the content you generated or connected to your account for that particular transaction.

2.14 Personal information we collect automatically when you use our Services

2.15 If you give us personal information about someone else, you must do so only with their consent. You undertake to inform them that you tend to provide or have provided us their personal information and tell them how we collect, use and disclose the personal information.

We also collect information about your interaction with our Services, advertising, or e-mail communications. This is typically information we receive from your computer or other devices, including your mobile devices:

2.15 If you give us personal information about someone else, you must do so only with their consent. You undertake to inform them that you tend to provide or have provided us their personal information and tell them how we collect, use and disclose the personal information.

3. For what purposes do we process your personal data?

3.1 Technical and functional management of the Site

We use the information that we gather from our users in a number of ways, including to provide and improve our services, for targeted online marketing, and to communicate with you. We also partner with service providers and other third parties that collect, use, and analyze information about TINAVAT users.

3.2 TINAVAT will not sell or disclose your personal information to third parties without your explicit consent, except as specified in our Privacy and Cookie Policy.

3.3 When you visit our Site, we may process technical data such as your IP-address, visited webpages, the internet browser you use, your previous/next visited Sites and the duration of a visit/session to enable us to deliver the functionalities of the Site. In addition, in certain instances the browser may prompt you for your geo-location to allow us to provide you with an enhanced experience. With this technical data our Site administrators can manage the Site, for instance by resolving technical difficulties or improving the accessibility of certain parts of the Site. This way, we ensure that you can, and will continue to, find the information on the Site in a quick and simple manner.

3.4 For this purpose we may also use cookies. See paragraph 9 for our cookie policy.

3.5 When you register as a user, we will collect your email address, a username and a password. We can also collect your real name, tax number, other identification number, physical address, phone number, Skype ID, website, blog, date of birth / foundation, other proof of identification if you provide it (e.g. for getting a proper invoice instead of a receipt). Besides the former data, we may collect your IP-address and MAC-address, too.

3.6 We will use your login email address to send you a welcoming email and to verify your email address, to communicate with you in response to your inquiries, and to send you service-related announcements, for instance, if our Service is temporarily suspended for maintenance. If you make a deal with someone through a successfully closed listing, we will let the other party know your login email address or the one you provided specially for this purpose in order to let you clarify whatever you may want.

3.7 We will use your registration information to create and manage your TINAVAT account. We may deactivate your account if we suspect that you use our Site to commit fraudulent or illegal acts or if you violate our terms of use. We may:

3.8 Customize our advertising and marketing communications with you

We may:

3.9 Detect, Prevent and Mitigate Fraudulent or Illegal Activities

If required, we may use your personal data:

3.10 Photo

If you choose to upload a photo to your TINAVAT account, your photo will be viewable by the other users. You may remove or replace your photo at any time by logging into your account on the Site.

3.11 Processing payments

After you became a registered user, you can use the Bank card validation function, where your credit card information is provided to our payment processing provider OTP Mobile Ltd. in order to process payments for your requests. TINAVAT itself gets only the first six (the BIN numbers) and the last four digits of your credit card number, the expiration date and (for the US) your zip code. We use this information to try to prevent fraud. Further we will submit your e-mail address and payment information to our e-wallet providers such as Paysera LT (www.paysera.com) or Skrill Ltd. (www.skrill.com) for processing of payments.

3.12 Generating management information and statistical data

TINAVAT uses your personal data in an anonymised and aggregated form to closely monitor which features of the Service are used most, to analyze usage patterns and to determine where we should offer or focus our Service. We may share this information with third parties for industry analysis and statistics.

3.13 Share

If you choose to use our referral feature in the Site to tell a friend about our Service, you will be prompted to enter your friend's email address or mobile phone number or log into your preferred social network. If you elect to refer a friend, we will automatically populate a message for you to send to your friend inviting him or her to try the Service on your behalf, however the actual message will be sent via your mobile device or social network and you will be able to edit the final message before you send it. We do not store your friend's data.

3.14 Administration of Public Forums

The Site may offer publicly accessible blogs and community forums. We will use your username, email address, the messages or content you choose to post to administrate and provide you with these services. You should be aware that any information you provide in these areas may be read, collected, and used by others who access them. To request removal of your contribution from our blog or community forum, please contact us through our customer service link provided on the Site.

4. Our Disclosure of Your Information

4.1 We may employ third party companies and individuals to facilitate or provide the Service on our behalf, to process payment, provide customer support, to perform Site-related services (e.g., without limitation, maintenance services, database management, web analytics and improvement of the Site's features) or to assist us in analyzing how our Service is used. These third parties have access to your personal information only to perform these tasks on our behalf and are contractually bound not to disclose or use it for any other purpose. The personal information so transferred may not be kept by these third parties longer than it is necessary for performing the relevant tasks.

4.2 TINAVAT will disclose your personal data to the extent that this is legally required, or necessary for the establishment, exercise or defense of legal claims and legal process; or in the event of an emergency pertaining to your health and/or safety.

4.3 We may disclose your personal information for the following purposes:

to TINAVAT corporate group members, who may use it to:

4.4 Users of our corporate family may use your information to send you marketing communications only if you have consented to receive such communications from them.

4.5 If we were to merge with or be acquired by another company, we may share information with them. Should such an event occur, we will require that the new combined entity follow this Privacy and Cookie Policy with respect to your personal information. If your personal information will be used or disclosed for any purposes not covered in this Privacy and Cookie Policy, you will receive prior notification of the use of your personal information for the new purposes.

4.6 Service Providers and Financial Institutions Partners

Third party service providers who help us operate our Services, payment infrastructure and assist with fraud investigations, bill collection and other business operations may receive certain information that you provided us.

4.7 People you authorize us to provide it to

TINAVAT users as authorized by you or your use of our Services (e.g. if you make a deal with another user through a successfully closed listing, the system sends a message to each party with - inter alia - the other party’s contact information, including email address, phone number, Skype ID to help complete the transaction).

4.8 Users, specially ones you make a del with by a successfully closed listing, have access to some information you share on TINAVAT. For example, all other users may see your public profile, the reviews you received, your listings, while people who made a deal with you may be able to see your bids.

4.9 Your User ID is displayed throughout TINAVAT and is available to the public. It is connected to all of your TINAVAT activity. Notices sent to other community users about suspicious activity and notice violations on our sites refer to User IDs and specific items. So if you associate your name with your User ID, the people to whom you have revealed your name will be able to personally identify your TINAVAT activities.

4.10 To help protect your privacy, we allow only limited access to other users' contact, shipping and financial information as necessary to facilitate your transactions and collect payments. However, when users are involved in a transaction, they have access to each other's name, User ID, email address and other contact and shipping information.

4.11 You may obtain personal information of others to complete transactions and collect payments. We encourage you to disclose your privacy practices and respect the privacy of other users. In all cases, you must give other users a chance to remove themselves from your database and a chance to review what information you have collected about them.

4.12 Use the personal information that you have access to only for TINAVAT transaction-related purposes, for using services offered through TINAVAT (such as escrow, shipping, and fraud complaints), and for purposes expressly consented by the user to whom the information relates. Using personal information that you have access to for any other purpose is a violation of our policies.

4.13 We take steps to ensure that you have the ability to access or correct your contact details, or any other information you provided.

5. Your rights

5.1 We appreciate users of our community value having control over their own information, and therefore TINAVAT gives you the choice of providing, editing or removing certain information, as well as choice over how we contact you.

5.2 You may change or correct your TINAVAT account information (except your login e-mail address) on the Site. You may also remove certain optional information on the Site that you no longer wish to be publicly visible or stored by us, such as your billing address.

5.3 For various reasons, TINAVAT may contact you about our Services or your activity. Some of these messages are required and are service-related messages for users. Other messages are not required, and you can control which optional messages you choose to receive by changing your settings in your account.

5.4 If you no longer wish to use TINAVAT’s Services or receive service-related messages, then you may close your account. You may also amend your personal details and withdraw any given consent using your TINAVAT account.

6. Retention

6.1 Unless specified otherwise in this Privacy and Cookie Policy, we will retain your information until you cancel your TINAVAT account, or until your TINAVAT account has been inactive for a year. If you wish to cancel your TINAVAT account or request that we no longer use your information to provide you services, please contact us through our customer service link available on the Site. After deletion of your account we will anonymize your data, unless these data are necessary to comply with a legal obligation or resolve disputes.

7. Minor’s Privacy and Parental Control

The Sites and their contents are not targeted to minors (those under the age of 18) and we do not intend to sell any of our products or services to minors. However, we have no way of distinguishing the age of individuals who access our Site. If a minor has provided us with personal information without parental or guardian consent, the parent or guardian should contact our Custom Service or our Site to remove the information.

8. Security

8.1 TINAVAT has taken appropriate technical and organizational security measures against loss or unlawful processing of your personal data. To this purpose, your personal data are securely stored within our database, and we use standard, industry-wide, commercially reasonable security practices such as encryption, firewalls and SSL (Secure Socket Layers) as well as physical safeguards of the locations where data are stored.

8.2 However, as effective as encryption technology is, no security system is impenetrable. We cannot guarantee the security of our database, nor can we guarantee that information you supply won't be intercepted while being transmitted to us over the Internet. Any transmission of information by you to TINAVAT is at your own risk. We recommend that you do not disclose your password to anyone.

9. Cookie policy

9.1 What are cookies, web beacons and similar technologies?

9.1.1 We may use technologies that are essentially small data files placed on your computer, tablet, mobile phone or other devices (referred to collectively as a “device”) that allow us to record certain pieces of information whenever you visit or interact with our Site, Services, applications, messaging and tools.

9.1.2 The specific names and types of the cookies, web beacons, and other similar technologies we use may change from time to time. In order to help you better understand our policy we have provided the following limited terminology and definitions:

9.1.3 We may use the terms “cookies” or “similar technologies” interchangeably in our policy to refer to all technologies that we may use to store data in your browser or device or that collect information or help us identify you in the manner described above.

9.2 What are cookies and similar technologies used for?

9.2.1 Cookies and similar technologies allow a site or services to know if your device has visited it before. These technologies can be used to deliver products, services, and ads that help us understand how the Site or Service is being used, help you to navigate between pages efficiently, reusing your preferences, and generally improve your experience in using our Services. Cookies can also help ensure marketing you see online is more relevant to you and your interests.

9.3 What types of cookies do we use?

9.3.1 There are generally four categories of cookies and we may routinely use all of them on the Service. You can find out more about each cookie category below:

9.4 How long will cookies stay on my device?

9.4.1 The length of time a cookie will stay on your device depends on whether it is a “persistent” or “session” cookie.

9.4.2 For instance, we may use cookies to store your language preferences or other settings so you do not have to set them up every time you visit our website. Some of the cookies we use are associated with your account (including personal information about you, such as the email address you gave us), and other cookies are not.

9.5 First and third party cookies

9.5.1 We may work with third-party companies, who may place third-party cookies or similar technologies for storing information on our Site or in our Services, applications, and tools with our permission. These third-party companies help us operate our Site, applications, Services, and tools, and provide you with a better, faster and safer experience.

9.5.2 Our Site, Services, applications and tools may use third parties, such as network advertisers and ad exchanges, to serve advertisements. These third-party ad networks and exchange providers may use third-party cookies, or similar technologies to collect information to provide you with their services. They may also collect your device identifier, IP address, or identifier for advertising (IDFA), which may be used to tailor the advertising you see on our sites or elsewhere on the web.

9.6 How to control cookies or other collection mechanisms

9.6.1 You are always free to block, delete, or disable cookies and similar technologies if your browser or device so permits.

9.6.2 Please note that if you set your browser to disable cookies, you may not be able to access certain parts of our Service and other parts of our Service may not work properly.

9.6.3 To learn more about the choices that advertisers provide generally for individuals to influence how information about their online activities over time and across third-party websites or online services is collected and used, visit the Network Advertising Initiative at http://www.networkadvertising.org/managing/opt_out.asp, the Digital Advertising Alliance at http://www.aboutads.info/, or the European Digital Advertising Alliance at http://youronlinechoices.eu/.

10. Changes in this Privacy and Cookie Policy

10.1 We may update this privacy statement to reflect changes to our information practices. If we make any material changes we will notify you by email and by means of a notice on the Site prior to the change becoming effective. We encourage you to periodically review this page for the latest information on our privacy practices.

11. Contact details

The services hereunder are offered by TMTM Limited, a private company limited by shares under the laws of Hong Kong having its main offices at Room 815, 8/F, Star House, 3 Salisbury Road, Tsim Sha Tsui, Kowloon, Hong Kong; registered at the Hong Kong Companies Registry with Company No. 2239791. If you have questions about this Privacy and Cookie Policy, please contact us at the Customer service link at our Site.