Jin Zang Si Treeesa LLC Privacy Policy, effective as of January 12, 2021

This Jin Zang Si Treeesa LLC Privacy Policy ("Privacy Policy") explains our privacy practices for the activities described herein. Please read this Privacy Policy carefully to learn how we collect, use, share, & otherwise process information relating to individuals ("Personal Data"), & to learn about your rights & choices regarding your Personal Data.

A reference to "Jin Zang Si Treeesa," "we," "us" or the "Company" is a reference to Jin Zang Si Treeesa LLC, a California limited liability company. Our address is 30025 Alicia Parkway, Suite 618, Laguna Niguel, CA 92677, USA.

1. Responsible entity

Jin Zang Si Treeesa LLC is the collector of your Personal Data as described in this Privacy Policy, unless specified otherwise. We are not responsible for the privacy or data security practices of any third party, which may differ from those explained in this Privacy Policy.

2. Activities covered

This Privacy Policy applies to the collection of Personal Data collected by us when you:

- Visit our websites that display or link to this Privacy Policy;
- Visit our offices;
- Receive communications from us, including emails, phone calls, texts or fax;
- Use our products or services;
- Register for, attend or take part in our seminars, sessions (private or group), events, or webinars.
When using our websites or applications that are provided by us, this Privacy Policy applies.

Our websites & services may contain links to other websites, applications, & services maintained by third parties. The information practices of other services, or of social media platforms that host our branded social media pages, are governed by their privacy policies, which you should review to better understand their privacy practices.

3. What Personal Data do we collect?

3.1 Personal Data we collect directly from you

The Personal Data we collect directly from you includes identifiers, personal, professional or employment-related information, financial account information, commercial information, visual information, & internet activity information. We collect such information in the following situations:

- If you express an interest in obtaining additional information about our services; use our "Contact Us" or similar features; register to use our website(s); sign up for an event, seminar, session (private or group), or webinar; or access or download certain content, we may require that you provide to us your contact information, such as your name, job title, company name, address, phone number, email address or username & password;
- If you register for an event, seminar, session (private or group), or webinar, we may require that you provide to us your financial & billing information, such as billing name & address, credit card number or bank account information;
- If you register for an online community that we host, we may ask you to provide a username, photo or other biographical information, such as your occupation, location, social media profiles, company name, areas of expertise & interests;
- If you interact with our websites or emails, we automatically collect information about your device & your usage of our websites or emails (such as Internet Protocol (IP) addresses or other identifiers), which may qualify as Personal Data (please see the "What device & usage data we process" section, below) using cookies, web beacons, or similar technologies;
- If you use & interact with our services, we automatically collect information about your device & your usage of our services through log files & other technologies, some of which may qualify as Personal Data (please see the "What device & usage data we process" section, below);
- If you voluntarily submit certain information to our services, such as filling out a survey about your user experience, we collect the information you have provided as part of that request; &
- If you visit our offices, you may be required to register as a visitor & to provide your name, email address, phone number, company name & time & date of arrival.

If you provide us or our service providers with any Personal Data relating to other individuals, you represent that you have the authority to do so, & where required, have obtained the necessary consent, & acknowledge that it may be used in accordance with this Privacy Policy. If you believe that your Personal Data has been provided to us improperly, or want to exercise your rights relating to your Personal Data, please contact us by using the information in the "Contacting us" section below.

3.2 Personal Data we collect from other sources

We may also collect information about you from other sources & other third parties from whom we get Personal Data & from publicly available information. We may combine this information with Personal Data provided by you. This helps us update, expand, & analyze our records, identify new customers, & create more tailored advertising to provide services that may be of interest to you. The Personal Data we collect from other sources includes identifiers, professional or employment-related information, education information, commercial information, visual information, internet activity information, & inferences about preferences & behaviors. In particular, we collect or may collect such Personal Data from the following sources:

- Third party providers of business contact information, including mailing addresses, job titles, email addresses, phone numbers, intent data (or user behavior data), IP addresses, social media profiles, LinkedIn URLs & custom profiles, for purposes of targeted advertising, delivering relevant email content, event promotion & profiling, determining eligibility & verifying contact information; &
- Another individual at your organization who may provide us with your business contact information for the purposes of obtaining services.

4. What device & usage data do we process?

We use common information-gathering tools, such as tools for collecting usage data, cookies, web beacons, pixels, & similar technologies to automatically collect information that may contain Personal Data as you navigate our websites, our services, or interact with emails we have sent to you.

4.1 Device & usage data

As is true of most websites, we gather certain information automatically when individual users visit our websites. This information may include identifiers, commercial information, & internet activity information such as IP address (or proxy server information), device & application information, identification numbers & features, location, browser type, plug-ins, integrations, Internet service provider &/or mobile carrier, the pages & files viewed, searches, referring website, app or ad, operating system, system configuration information, advertising & language preferences, date & time stamps associated with your usage, & frequency of visits to the websites. This information is used to analyze overall trends, help us provide & improve our websites, offer a tailored experience for website users, & secure & maintain our websites.

In addition, we gather certain information automatically as part of your use of our products & services. This information may include identifiers, commercial information, & internet activity information such as IP address (or proxy server), mobile device number, device & application identification numbers, location, browser type, Internet service provider or mobile carrier, the pages & files viewed, website & webpage interactions including searches & other actions you take, operating system & system configuration information & date & time stamps associated with your usage. This information is used to maintain the security of the services, to provide necessary functionality, to improve performance of the services, to assess & improve customer & user experience of the services, to review compliance with applicable usage terms, to identify future opportunities for development of the services, to assess capacity requirements, to identify customer opportunities, & for the security of Treeesa generally (in addition to the security of our products & services). Some of the device & usage data collected by the services, whether alone or in conjunction with other data, could be personally identifying to you. Please note that this device & usage data is primarily used to identify the uniqueness of each user logging on (as opposed to specific individuals), apart from where it is strictly required to identify an individual for security purposes or as required as part of our provision of the services to our customers.

4.2 Cookies, web beacons & other tracking technologies on our website & in email communications

We use technologies such as web beacons, pixels, tags, & JavaScript, alone or in conjunction with cookies, to gather information about the use of our websites & how people interact with our emails.

When you visit our websites, we, or an authorized third party, may place a cookie on your device that collects information, including Personal Data, about your online activities over time & across different sites. Cookies allow us to track use, infer browsing preferences, & improve & customize your browsing experience.

We use both session-based & persistent cookies on our websites. Session-based cookies exist only during a single session & disappear from your device when you close your browser or turn off the device. Persistent cookies remain on your device after you close your browser or turn your device off. To change your cookie settings & preferences for one of our websites, please contact us by using the information in the "Contacting us" section below. You can also control the use of cookies on your device, but choosing to disable cookies on your device may limit your ability to use some features on our websites & services.

We also use web beacons & pixels on our websites & in emails. For example, we may place a pixel in marketing emails that notify us when you click on a link in the email. We use these technologies to operate & improve our websites & marketing emails. For instructions on how to unsubscribe from our marketing emails, please see Section 10.3 below.

4.3 Notices on behavioral advertising & opt-out for website visitors

As described above, we or one of our authorized partners may place or read cookies on your device when you visit our websites for the purpose of serving you targeted advertising (also referred to as "online behavioral advertising" or "interest-based advertising"). To opt-out of targeted advertising that is provided to us & to third parties by us, please contact us by using the information in the "Contacting us" section below.

4.4 Opt-Out from the setting of cookies on your individual browser

In many cases you may opt-out from the collection of non-essential device & usage data on your web browser (see the "What device & usage data we process" section, above) by managing your cookies at the browser or device level. Please note, however, that by blocking or deleting cookies & similar technologies used on our websites, you may not be able to take full advantage of the websites.

While some internet browsers offer a "do not track" or "DNT" option that lets you tell websites that you do not want to have your online activities tracked, these features are not yet uniform & there is no common standard adopted by industry groups, technology companies, or regulators. Therefore, we do not currently commit to responding to browsers' DNT signals with respect to our websites. Jin Zang Si Treeesa takes privacy & meaningful choice seriously & will make efforts to continue to monitor developments around DNT browser technology & the implementation of a standard.

4.5 Social Media Features

Our websites may use social media features ("Social Media Features"). Social Media Features may allow you to post information about your activities on our website to outside platforms & social networks. Social Media Features may also allow you to highlight information we have posted on our website. Social Media Features are either hosted by each respective platform or hosted directly on our website. To the extent the Social Media Features are hosted by the platforms themselves, & you click through to these from our websites, the platform may receive information showing that you have visited our websites. If you are logged in to your social media account, it is possible that the respective social media network can link your visit to our websites with your social media profile.

Jin Zang Si Treeesa also allows you to log in to certain of our websites using sign-in services. These services authenticate your identity & provide you the option to share certain Personal Data from these services with us such as your name & email address to pre-populate our sign-up form.

Your interactions with Social Media Features are governed by the privacy policies of the companies providing them.

4.6 Telephony log information

If you use certain features of our services on a mobile device, we may also collect telephony log information (like phone numbers, time & date of calls, duration of calls, SMS routing information & types of calls), device event information (such as crashes, system activity, hardware settings, browser language), & location information (through IP address, GPS, & other sensors that may, for example, provide us with information on nearby devices, Wi-Fi access points & cell towers).

5. Purposes for which we process Personal Data & the legal bases on which we rely

We collect & process your Personal Data for the following purposes. Where required by law, we obtain your consent to use & process your Personal Data for these purposes. Otherwise, we rely on another authorized legal basis (including but not limited to the (a) performance of a contract or (b) legitimate interest) to collect & process your Personal Data.

- Providing our websites & services: We process your Personal Data to perform our contract with you for the use of our websites & services & to fulfill our obligations under the applicable terms & conditions of use; if we have not entered into a contract with you, we base the processing of your Personal Data on our legitimate interest to operate & administer our websites & to provide you with content you access & request (e.g., to download content from our websites);
- Promoting the security of our websites & services: We process your Personal Data by tracking use of our websites & services, creating aggregated non-personal data, verifying accounts & activity, investigating suspicious activity, & enforcing our terms & policies to the extent it is necessary for our legitimate interest in promoting the safety & security of the services, systems & applications & in protecting our rights & the rights of others;
- Providing necessary functionality: We process your Personal Data to perform our contract with you for the use of our websites & services; if we have not entered into a contract with you, we base the processing of your Personal Data on our legitimate interest to provide you with the necessary functionality required for your use of our websites & services;
- Managing user registrations: If you have registered for an account with us, we process your Personal Data by managing your user account for the purpose of performing our contract with you according to applicable terms of a service agreement;
- Handling contact & user support requests: If you fill out a contact web form or request user support, or if you contact us by other means including via a phone call, we process your Personal Data to perform our contract with you & to the extent it is necessary for our legitimate interest in fulfilling your requests & communicating with you;
- Managing event registrations & attendance: We process your Personal Data to plan & host events, seminars, sessions (private or group), or webinars for which you have registered or that you attend, including sending related communications to you, to perform our contract with you;
- Managing payments: If you have provided financial information to us, we process your Personal Data to verify that information & to collect payments to the extent that doing so is necessary to complete a transaction & perform our contract with you;
- Developing & improving our websites & services: We process your Personal Data to analyze trends & to track your usage of & interactions with our websites & services to the extent it is necessary for our legitimate interest in developing & improving our websites & services & providing our users with more relevant content & service offerings, or where we seek your valid consent;
- Assessing & improving user experience: We process device & usage data as described in Section 4.1 above, which in some cases may be associated with your Personal Data, to analyze trends & assess & improve the overall user experience to the extent it is necessary for our legitimate interest in developing & improving the service offering, or where we seek your valid consent;
- Reviewing compliance with applicable usage terms: We process your Personal Data to review compliance with the applicable usage terms in our customer's contract to the extent that it is in our legitimate interest to ensure adherence to the relevant terms;
- Assessing capacity requirements: We process your Personal Data to assess the capacity requirements of our services to the extent that it is in our legitimate interest to ensure that we are meeting the necessary capacity requirements of our service offering;
- Identifying customer opportunities: We process your Personal Data to assess new potential customer opportunities to the extent that it is in our legitimate interest to ensure that we are meeting the demands of our customers & their users' experiences;
- Registering office visitors: We process your Personal Data for security reasons, to register visitors to our offices & to manage non-disclosure agreements that visitors may be required to sign, to the extent such processing is necessary for our legitimate interest in protecting our offices & our confidential information against unauthorized access;
- Displaying personalized advertisements & content: We process your Personal Data to conduct marketing research, advertise to you, provide personalized information about us on & off our websites & to provide other personalized content based upon your activities & interests to the extent it is necessary for our legitimate interest in advertising our websites or, where necessary, to the extent you have provided your prior consent (please see the "Your rights relating to your Personal Data" section, below, to learn how you can control how the processing of your Personal Data by us for personalized advertising purposes);
- Sending marketing communications: We may process your Personal Data or device & usage data, which in some cases may be associated with your Personal Data, to send you marketing information, product recommendations & other non-transactional communications (e.g., marketing newsletters, telemarketing calls, SMS, or push notifications) about us & our affiliates & partners, including information about our products, promotions or events as necessary for our legitimate interest in conducting direct marketing or to the extent you have provided your prior consent (please see the "Your rights relating to your Personal Data" section, below, to learn how you can control the processing of your Personal Data by Jin Zang Si Treeesa for marketing purposes); &
- Complying with legal obligations: We process your Personal Data when cooperating with public & government authorities, courts or regulators in accordance with our legal obligations under applicable laws to the extent this requires the processing or disclosure of Personal Data to protect our rights or is necessary for our legitimate interest in protecting against misuse or abuse of our websites, protecting personal property or safety, pursuing remedies available to us & limiting our damages, complying with judicial proceedings, court orders or legal processes, respond to lawful requests, or for auditing purposes.

If we need to collect & process Personal Data by law, or under a contract we have entered into with you, & you fail to provide the required Personal Data when requested, we may not be able to perform our contract with you.

6. Who do we share Personal Data with?

We may share your Personal Data as follows:

- Service Providers: With our contracted service providers, who provide services such as IT & system administration & hosting, credit card processing, research & analytics, marketing, customer support & data enrichment for the purposes & pursuant to the legal bases described above;
- Affiliates: If you use our websites to register for an event, seminar, session (private or group), or webinar organized by one of our affiliates, we may share your Personal Data with the affiliate to the extent this is required on the basis of the affiliate's contract with you to process your registration & ensure your participation in the event; in such instances, our affiliate will collect the relevant Personal Data & will provide you with further information on the collection & use of your Personal Data, where required;
- Event Sponsors: If you attend an event, seminar, session (private or group), or webinar organized by us, or download or access an asset on our website, we may share your Personal Data with sponsors of the event. If required by applicable law, you may consent to such sharing via the registration form. In these circumstances, your information will be subject to the sponsors' privacy policies. If you do not wish for your information to be shared, you may choose to not opt-in via event/webinar registration or you can opt-out in accordance with Section 10 below;
- Third party networks & websites: With third-party social media networks, advertising networks & websites, so that Jin Zang Si Treeesa can market & advertise on third party platforms & websites;
- Professional Advisers: In individual instances, we may share your Personal Data with professional advisers acting as service providers, processors, or joint controllers - including lawyers, bankers, auditors, & insurers who provide consultancy, banking, legal, insurance & accounting services, & to the extent we are legally obliged to share or have a legitimate interest in sharing your Personal Data; &
- Third Parties Involved in a Corporate Transaction: If we are involved in a merger, reorganization, dissolution or other fundamental corporate change, or sell a website or business unit, or if all or a portion of our business, assets or stock are acquired by third party, with such third party. In accordance with applicable laws, we will use reasonable efforts to notify you of any transfer of Personal Data to an unaffiliated third party.

We may also share anonymous or de-identified usage data with our service providers for the purpose of helping Jin Zang Si Treeesa in such analysis & improvements. Additionally, Jin Zang Si Treeesa may share such anonymous or de-identified usage data on an aggregate basis in the normal course of operating our business; for example, we may share information publicly to show trends about the general use of our services.

Anyone using our communities, forums, blogs, or chat rooms on our websites may read any Personal Data or other information you choose to submit & post.

For more information on the recipients of your Personal Data, please contact us by using the information in the "Contacting us" section, below.

7. International transfer of Personal Data

We do not currently share, transfer or store your Personal Data outside of the United States of America. If at any time we do intend to share, transfer or store your Personal Data outside of the United States of America, we will only share, transfer or store your Personal Data outside of the United States of America with your prior consent.

8. Children

Our websites are not directed at children. We do not knowingly collect Personal Data from children under the age of 16. If you are a parent or guardian & believe your child has provided us with Personal Data without your consent, please contact us by using the information in the "Contacting us" section below & we will take steps to delete their Personal Data from our systems.

9. How long do we keep your Personal Data?

We may retain your Personal Data for a period of time consistent with the original purpose of collection (see the "Purposes for which we process Personal Data & the legal bases on which we rely" section, above) or as long as required to fulfill our legal obligations. We determine the appropriate retention period for Personal Data on the basis of the amount, nature, & sensitivity of the Personal Data being processed, the potential risk of harm from unauthorized use or disclosure of the Personal Data, whether we can achieve the purposes of the processing through other means, & on the basis of applicable legal requirements (such as applicable statutes of limitation).

After expiry of the applicable retention periods, your Personal Data will be deleted. If there is any data that we are unable, for technical reasons, to delete entirely from our systems, we will implement appropriate measures to prevent any further use of such data.

For more information on data retention periods, please contact us by using the information in the "Contacting us" section, below.

10. Your rights relating to your Personal Data

10.1 Your rights

You may have certain rights relating to your Personal Data, subject to local data protection laws. Depending on the applicable laws these rights may include the right to:

- Access your Personal Data held by us;
- Know more about how we collect & use your Personal Data;
- Rectify inaccurate Personal Data &, taking into account the purpose of processing the Personal Data, ensure it is complete;
- Erase or delete your Personal Data (also referred to as the right to be forgotten), to the extent permitted by applicable data protection laws;
- Restrict our processing of your Personal Data, to the extent permitted by law;
- Transfer your Personal Data to another collector or processor, to the extent possible (right to data portability);
- Object to any use of your Personal Data. Where we use your Personal Data for direct marketing purposes or share it with third parties for their own direct marketing purposes, you can exercise your right to object at any time to such use without having to provide any specific reason for such objection;
- Opt out of certain disclosures of your Personal Data to third parties;
- If you're under the age of 16, opt in to certain disclosures of your Personal Data to third parties;
- Not be discriminated against for exercising your rights described above;
- Not be subject to a decision based solely on automated processing, including profiling, which produces legal effects ("Automated Decision-Making"). Automated Decision-Making currently does not take place on our websites or in our services; &
- Withdraw your consent at any time (to the extent we base processing on consent), without affecting the lawfulness of the processing based on such consent before its withdrawal.

10.2 How to exercise your rights

To exercise your rights, please contact us by using the information in the "Contacting us" section, below. We try to respond to all legitimate requests within one month & will contact you if we need additional information from you in order to honor your request. Occasionally it may take us longer than a month, taking into account the complexity & number of requests we receive.

Some registered users may update their user settings, profiles, organization settings & event registrations by logging into their accounts & editing their settings or profiles.

To update your billing information, discontinue your account or request return or deletion of your Personal Data & other information associated with your account, please contact us by using the information in the "Contacting us" section, below.

10.3 Your preferences for email & SMS marketing communications

If we process your Personal Data for the purpose of sending you marketing communications, you may manage your receipt of marketing & non-transactional communications from Jin Zang Si Treeesa by notifying us using the information in the "Contacting us" section below or by replying or texting “STOP” if you receive SMS communications from us.

Please note that opting out of marketing communications does not opt you out of receiving important business communications related to your current relationship with us, such as communications about your subscriptions or event registrations, service announcements or security information.

10.4 Your preferences for telemarketing communications

If we contact you, directly or indirectly, using telemarketing communications, you can always let us know during a telemarketing call that you do not want to be called again for marketing purposes.

11. How we secure your Personal Data

We take appropriate precautions including organizational, technical, & physical measures to help safeguard against accidental or unlawful destruction, loss, alteration, & unauthorized disclosure of, or access to, the Personal Data we process or use.

While we follow generally accepted standards to protect Personal Data, no method of storage or transmission is 100% secure. You are solely responsible for protecting your password, limiting access to your devices & signing out of websites after your sessions. If you have any questions about the security of our websites, please contact us by using the information in the "Contacting us" section, below.

12. Changes to this Privacy Policy

We will update this Privacy Policy from time to time to reflect changes in our practices, technologies, legal requirements, & other factors. If we do, we will update the "effective date" at the top. If we make a material update, we may provide you with notice prior to the update taking effect, such as by posting a conspicuous notice on our website or by contacting you directly, or where required under applicable law & feasible, seek your consent to these changes.

We encourage you to periodically review this Privacy Policy to stay informed about our collection, processing & sharing of your Personal Data.

13. Contacting us

To exercise your rights regarding your Personal Data, or if you have questions regarding this Privacy Policy or our privacy practices please email us at: [email protected] , or write to us at:

Jin Zang Si Treeesa LLC
30025 Alicia Parkway, Suite 618,
Laguna Niguel, CA 92677, USA

We are committed to working with you to obtain a fair resolution of any complaint or concern about privacy.

14. Additional Disclosures for California Residents

The California Consumer Privacy Act (CCPA) requires businesses to disclose whether they sell Personal Data. As a business covered by the CCPA, we do not sell Personal Data. We may share Personal Data with third parties or allow them to collect Personal Data from our sites or Services if those third parties are authorized service providers or business partners who have agreed to our contractual limitations as to their retention, use, & disclosure of such Personal Data, or if you use Jin Zang Si Treeesa sites or Services to interact with third parties or direct us to disclose your Personal Data to third parties.

California law requires that we detail the categories of Personal Data that we share or disclose for certain "business purposes," such as disclosures to service providers that assist us with securing our services or marketing our products. We disclose the following categories of Personal Data for our business purposes:

- Identifiers;
- Commercial information;
- Internet activity information;
- Financial information;
- Professional & employment-related information;
- Education information; &
- Inferences drawn from any of the above information categories.

California law grants state residents certain rights, including the rights to access specific types of Personal Data, to learn how we process Personal Data, to request deletion of Personal Data, & not to be denied goods or services for exercising these rights.

If you are a California resident under the age of 18 & have registered for an account with us, you may ask us to remove content or information that you have posted to our website(s). Please note that your request does not ensure complete or comprehensive removal of the content or information, because, for example, some of your content may have been reposted by another user.

For information on how to exercise your rights, please refer to Section 10.2 of this Privacy Policy. If you are an authorized agent wishing to exercise rights on behalf of a California resident, please contact us using the information in the "Contacting Us" section above & provide us with a copy of the consumer's written authorization designating you as their agent.

We may need to verify your identity & place of residence before completing your rights request.