Data Privacy Policy

This is the privacy policy of Sino Associates Consulting Limited registered in China with its registered address at R1510，15/F，A8 Building No. 99 Gaoxin 9th Road South, High Tech Park, Nanshan Disrict, Shenzhen, China. When we refer to "Shenzhen Sino", "we", or "our", we mean Sino Associates Consulting Limited as the data controller or processor.

Introduction

Sino Associates Sino Associates Consulting Limited to protecting and respecting your privacy. This privacy policy explains how we process data, including how we collect, store, and use personal data, the legal bases for processing your personal data, information regarding third-party disclosure and international transfers, and your rights as a data subject.

Our Approach to Privacy

We take a layered approach to privacy and data protection:

• This privacy policy explains how we process personal data.
• We also use privacy notices at various touchpoints on our website and other systems to collect personal data.

Table of Contents
This privacy policy includes:

1. [Who we are and other important information]
2. [What personal data we collect]
3. [How and when we collect your personal data]
4. [How and why, we use your personal data]
5. [Who we disclose your personal data to]
6. [International transfers of personal data]
7. [How we keep your data secure]
8. [Data retention and anonymization]
9. [Your legal rights]
10. [Changes to your personal data]
11. [How to access personal data we hold about you]
12. [How to contact us and exercise your complaint rights]
13. [Governing law]
14. [Status and changes to this privacy policy]
15. [Glossary of terms]
16. [Appendix Explanation of Demographic Data]

1. Who we are and other important information.

This section explains the scope of this privacy policy and who we are and other important information, including the regulatory bodies and affiliated entities related to us.

This is the privacy policy of Sino Associates Consulting Limited. It explains how we collect and process personal data by our products and services, our website, and the collection and processing of personal data for our psychological assessments. Our psychological assessments are designed for adults; therefore, our assessments and website are not intended for children (under 18) and we do not intentionally collect data about children. When we refer to "we" and "our" it refers to Sino Associates Consulting Limited. The language versions of this privacy policy include Chinese and English. Section 12 will tell you how to contact us.

2. What personal data we collect

This section explains "what types of personal data we may collect" and the categories of such data (Section 2.1). It includes information on special category data that we may collect (data that you may consider sensitive) (Section 2.3).

2.1 Whether you are a customer, supplier, or other business contact, survey respondent or employee, we will collect and use your personal data in accordance with the manner and reasons set out in this privacy policy. Most of our personal data is collected directly from you, but if we collect personal data indirectly, we will clearly state it in this privacy policy. The types of personal data that we may collect from individuals based on their relationship with us are listed below:

Customer Contact:

• Identity information (name, position, work email, phone, company name, request information)
• Technical data (including Internet Protocol (IP) address, login data, browser type and version on the device used to access our website, as well as other platforms, systems, and technologies we provide)

Supplier:

• Identity information (username, password, work email, phone, company name)
• Technical data (including Internet Protocol (IP) address, login data, browser type and version on the device used to access our website, as well as other platforms, systems, and technologies we provide)

Data will be collected in order for us to provide services, manage contractual relationships, perform account management, and provide you with updates and news, products, and services that we believe may be of interest to you.

Survey, evaluation, and learning participants:

Mandatory data:

• Identity data (including full name, username or similar identifier, position, work email, phone, company name)
• Contact data (including email address)
• Answers and personal preference data required to complete activities and survey questionnaires.

Non-mandatory data:

• In the questionnaire, we provide the following information based on web-based rating and delivery platforms:
  • Age group, without specific age required.
  • Nationality
  • Gender orientation/gender recognition
  • Current country
  • Application language
  • Employment status
  • Occupational level
  • Type of work

We will collect data from the respondents who participate in our survey, complete the survey, and conduct scoring and generate reports. In addition, if you participate in measurement, evaluation, development centers or other consulting activities organized by our professional service team, you may provide us with more data than the above data, which will be collected by practitioners, affiliated organizations or our professional service team and used to provide services.

In some cases, we collect special category data (such as the above-mentioned race information) from the respondents who participate in our survey and may collect them in the evaluation center or other consulting activities. Collection of such special category data is optional and provided only by the data subjects themselves. We collect race information and other optional demographic information to generate statistical data described in our technical product manual, such as psychological measurement standards and validity data, to ensure fairness, effectiveness, and reliability of statistical evaluation. These statistical data help to ensure that our assessments remain ethical and neutral, fair in different nationalities, races, and cultures, and support diversity and fairness. For more information about the research data, we collect and the reasons for it, please see our "Explanation of Demographic Data" page. These data are only used for research and product development purposes in aggregate and anonymous form (see Sections 2.2 and 4.1).

Visitors to the website of Sino Associates Consulting Limited and other platforms and technologies we provide may have data collected if they provide the following information:

• Identity data (including full name, username or similar identifier, position, company name)
• Contact data (including email address, phone number)
• Technical data (including internet protocol (IP) address, login data, browser type and version, and other technologies used on the device used to access our website)
• Usage data (including information about how you use our website, products, and services as well as other platforms, systems, and technologies)

Job applicants

If you apply for our job online, we will collect data from job applicants. If the application is not made online, the data may only include identity data and contact information as well as other information provided by the candidate. Candidates can request a copy of our privacy statement from the Human Resources Department of Sino Associates Consulting Limited. The statement provides information on the types of personal data provided by all employees when they start working, as well as information on collection, use, transfer to third parties, and the rights of data subjects.

Respondents participating in surveys for research and product development purposes.

Personal data may be collected from individuals participating in surveys we conduct voluntarily as part of our research and product development activities. Surveys may involve the collection of personal data and in some cases may include special categories of data. The collection of such special categories of data is optional and is only provided by the survey participant. Special categories of data are only used for research and product development purposes in aggregated and anonymous form (see sections 2.2 and 4.1).

Employee

We provide a privacy statement which lists the types of personal data collected, used, transferred to third parties, and the rights of data subjects. This applies to all employees upon employment/service commencement. More information about employees is not provided in this privacy policy; please contact the human resources department of Sino Associates Consulting Limited for more information.

2.2 Special categories of data

We do not collect special categories of data (including detailed information about race or ethnicity, religious beliefs, sexual orientation, health, and genetic and biometric data) except for specific measurements, survey respondents, and survey participants.

2.3 If you fail to provide personal data.

If we need to collect personal data in accordance with legal or contractual arrangements, and you fail to provide mandatory data when requested, we may be unable to fulfill our contractual or relationship terms with you.

2.4 COOKIE Policy

This policy explains the purposes for which we use cookies and similar technologies on this website and provides you with a settings interface to authorize or revoke your consent to the use of cookies. You can give or withdraw your consent at any time.

2.4.1 What are Cookies?

Cookies are small data files that are stored on your computer or mobile device when you visit a website. Cookies are widely used by website owners to make their websites work better or more efficiently and to report information. When you visit our website, cookies are downloaded from the browser to your terminal device, and the cookies set by the website owner are called "first-party cookies." Cookies set by parties other than the website owner are called "third-party cookies." Third-party cookies allow recognition of you on the website or other websites that provide third-party functionality (such as advertising, analytics, and interactive data).

2.4.1 Why do we use Cookies?

We use both first-party and third-party cookies for specific reasons. For technical requirements, we need to create some cookies to ensure the proper functioning of our website, and we refer to these cookies as "strictly necessary." Other cookies enable us to gain further insights into user preferences and enhance the user's interaction experience on our website.

2.4.2 Your Personal Information

When you visit our website, we use cookies to ensure you have the best experience on our website. These cookies may be related to you, your preferences, or your device. This information is usually not used to directly identify you but provides you with a more personalized website experience. We respect your rights regarding personal information, and you can choose to disable certain types of cookies. However, blocking certain types of cookies may impact your website experience and the services we can provide to you. We will use cookies to record the choices you make in our cookie management interface. This will have the following consequences:

• If you delete your cookies, you will need to inform us of your preferences again when you revisit our website.
• If you use different devices or browsers to access our website, you will need to inform us of your preferences again.

2.4.3 Strictly Necessary Cookies

These cookies are essential for the operation of our website and cannot be disabled in our systems. They are usually set in response to actions you take, which are equivalent to requesting services. You can set your browser to block these cookies, but some parts of the website will not function properly. Strictly necessary cookies do not store any personally identifiable information.

2.4.4 Functional Cookies

We use these cookies to remember your preferences and provide you with multimedia content that meets your technical requirements. We aggregate all the information collected by these cookies anonymously. If you disable these cookies, certain functionalities (such as videos) may become unavailable.

2.4.5 Statistical and Analytical Cookies

We use these cookies to understand how visitors interact with our website and gain insights into the activity within each page. If you disable these cookies, we will not know when you have visited our website and will be unable to optimize website functionality. This website uses Baidu Analytics, and you can view Baidu Analytics' privacy policy at: https://tongji.baidu.com/web/help/article?id=330&type=0&castk=LTE%3D

2.4.6 Marketing and Targeting Cookies

We use these cookies to provide you with relevant advertisements, content, or push notifications and deliver more personalized marketing messages to the right users, while preventing the same ads from being repeatedly shown to the same users. If you disable these cookies, we will be unable to provide you with advertisements and marketing recommendations that are tailored to your specific circumstances.

2.4.7 How to Control Your Cookies?

You have the right to decide whether to accept or reject the use of cookies on the website. You can set the use of cookies by adjusting your browser settings. The options in the cookie settings allow you to choose to accept or reject the collection of cookies. Strictly necessary cookies cannot be rejected as they are a strict requirement for providing you with the service. Taking Chrome browser as an example, users can manage website cookie collection requests by clicking on Settings-Advanced-Privacy and Security-Site Settings. You can disable cookies other than "strictly necessary cookies" through this page.

2.4.8 Your Rights and Contact Information

For more information about your rights regarding the processing of your personal data, and for inquiries and complaints, please visit the Privacy Policy.

2.4.9 How often is the Cookie Policy updated?

We may update this Cookie Policy from time to time or for other operational, legal, or regulatory reasons to reflect changes in the cookies we use. Therefore, please review this Cookie Policy periodically to understand how we use cookies and related technologies. The date at the top of this Cookie Policy indicates the most recent update.

3. How and when we collect your personal data

This section explains how and when we collect your personal data. Our servers and databases are located on Alibaba Cloud servers. Web services use https encryption for transmission.

3.1 We may collect your personal data directly through the following means: customers and suppliers (including individual contractors) and other business contacts will collect data:

• When you request our products and services, that is, before, during, and during the contract relationship.
• When you fill out forms for our website or products and services, including registering to use our website, subscribing to our services, posting materials, or using other services.
• When you participate in offline or online promotional activities hosted by us
• When you contact us, report issues to us, provide feedback, or complete surveys.
• When you place an order with us through our website, by phone, or by email.

Survey participants

When you participate in the survey, we start collecting data. The data may also come from your affiliated organizations. If feedback is given or if you participate in evaluations, development centers, or other consulting activities organized by our professional service teams, the above data may be provided to practitioners, affiliated organizations, or our professional service teams for feedback, evaluation, or participation.

Visitors accessing the website of Sino Associates Consulting Limited and other platforms and technologies that we provide.

Simply accessing the website of Sino Associates Consulting Limited does not require you to submit personal data. However, if you request information from us, register, sign up for our events or online activities, receive our marketing materials or express interest in our products or services in any other way, or report issues, any personal data submitted to us through our website or other platforms and technologies will be collected.

Job candidates

Data will be collected from job candidates when they apply for our positions, whether online, by mail, or through intermediaries, and throughout any subsequent interactions during the recruitment process.

Survey participants for research and product development purposes

Regarding the collection of any personal data by individuals participating in our survey:

• It may be used for research and product development purposes to generate the statistical data described in our technical product manuals, such as psychometric standards and validity data, to statistically evaluate fairness, effectiveness, and reliability of our assessments, ensuring that our evaluations remain ethical and neutral, fair across nationalities, races, and cultures, supporting diversity, fairness, and inclusivity. Additionally, we may collect individual data through surveys for research, supporting diversity, fairness, and inclusivity and other personality or behavioral aspects related to our products, such as leadership, stress, culture, inclusivity, and personality type.
• As part of the survey, you will be asked to consent to the use of your personal data for research and product development. If you refuse to do so, the data will not be collected or used for research and product development purposes. If you agree, the collected personal data may include data of special categories (as described in section 2), if you submit such data, this data will only be disclosed to third parties or published in the form of aggregated data, as described in section 2, and thus will not identify or be identifiable to any individual.

We will not contact you to share the results of your participation in the survey unless you follow up or request us to do so.

Automation Technology or Interaction

When you visit our website and access our resources on other platforms and technologies, we may automatically collect technical and usage data.

4. How we use your personal data and why we use it

This section explains how we use your personal data (section 4.1), as well as the legal basis for processing your data (section 4.2).

4.1 How we use your personal data and why we use it.

Customers and suppliers (including individual contractors) and other business contacts.

Customers' personal data (including identity, contact, technical, usage and profile data) will be used for:

• Providing you with the products and services you have requested from us.
• Managing our contractual relationship with you
• Carrying out customer management, including fulfilling any obligations arising from any contracts we have entered with you, including retaining correspondence you have with us.
• Personalizing the services we provide to you, including ensuring that the content on our website is presented in the most effective manner for you and your computer.
• Seeking your views on the products and services we provide.
• Allowing you to participate in interactive features of our services (only if you choose to do so, including real-time chat features).
• For technical management of our website, including notifying you about any changes to our services.
• Providing further information about our products and services.

Suppliers' and other business contacts' personal data (including identity, contact, technical, usage and profile data) will be used for:

• Receiving products and services
• Managing our contractual relationship with you
• Supplier management, including fulfilling any obligations arising from any contracts we have entered with you, including retaining correspondence you have with us.
• Providing you with updates and news related to our products and services in relation to the services you provide to us.

Survey respondents

Personal data collected from survey respondents through psychological measurement questionnaires will be used by us as a data processor for:

• Providing personalized computer-generated reports to survey respondents completing our psychological measurement questionnaires, as requested by the survey respondents. Occasionally, we may combine survey respondent data with data from other survey respondents, for example, to create team reports.
• Used for the purpose of feedback sessions between survey respondents and practitioners if feedback is given.
• Other data you provide may be used for the purpose of providing our services if you participate in an assessment or development center or other consulting project run by our professional services team.
• Used for research and product development. Such information is used for research and product development purposes by completing our psychological measurement questionnaires to produce statistical data described in our technical product manual, such as psychological measurement standards and validity data, to statistically evaluate the fairness, effectiveness, and reliability of our assessments in different nationalities, races, and cultures. These statistical data help ensure that our assessments remain ethical and neutral and are fair in different nationalities, races, and cultures, supporting diversity and fairness. For more information about the research data, we collect and its reasons, please see “Explanation of Demographic Data”. As part of the assessment process, you may be asked to agree to the use of your personal data for research and product development to answer additional optional research questions. If you refuse to do so, certain data will not be collected or used for research and product development purposes. If you agree, the personal data collected may include special category data (as described in section 2), and if you have submitted such data, it will only be disclosed to third parties or published in aggregate data form as described in section 2, so that no one can be identified or identifiable.

Visitors to Sino Associates Consulting Limited’s website and other platforms and technologies we provide.

Personal data (including identity, contact, technical and usage) will be used to form what we believe you may want or need, or what products, services or offers may interest you (known as marketing) to provide you with further information about our other products and services.

Job candidates

Candidate data will be used to assess suitability for a position as part of the recruitment process. Any data collected before employment starts will be treated in accordance with the Sino Associates Consulting Limited and affiliated company employee privacy statement.

Survey participants for research and product development purposes

For any personal data collected from individuals participating in our surveys:

• May be used for research and product development purposes to produce statistical data described in our technical product manual, such as psychological measurement standards and validity data, to statistically evaluate the fairness, effectiveness, and reliability of our assessments in different nationalities, races, and cultures, supporting diversity, fairness, and inclusion. In addition, we may collect individual data through surveys to support research, behavior, or other research related to our products, such as studies related to leadership, stress, culture, inclusivity, and other personality or behavioral aspects related to personality types.
• As part of the survey, you will be asked to agree to the use of your personal data for research and product development. If you refuse to do so, data will not be collected or used for research and product development. If you agree, the personal data collected may include special category data (as described in section 2), and if you have submitted such data, it will only be published or shared with third parties in aggregate data form as described in section 2, so that no one can be identified or identifiable.

We will not contact you because of your participation in a survey unless it is part of follow-up actions of the survey, or you request us to do so.

Aggregated Data

We also use aggregated data, including (i) survey respondent data collected from survey answers and optional question answers completed before completing the questionnaire (ii) data from survey participants for research and product development purposes. The aggregated data used in our research and product development functions is derived from your personal data but will not publish or disclose personal data because it is aggregated and anonymized for research and product development purposes, so no one can be identified or identifiable from this type of data.

Analytics

We also perform analytics, such as trends, sales intelligence, marketing effectiveness (such as click and open rates), acceptance and progression.

4.2 Legal basis for data processing

The purposes for which we use your data are set out below - these are typically referred to as the legal bases for processing your data. We may use multiple legal bases for each data element to process your personal data. Detailed information can be provided upon request. We generally do not rely on consent as a legal basis for processing your personal data, except in cases of sending marketing communications to certain prospective customers and collecting special category data from survey respondents. When consent is used as a legal basis for processing, you may withdraw your consent at any time, see section 9 for more information.

Consent:

Purpose	Legal basis for processing (including legitimate interests)
Customers Register customers and manage relationships. Provide updates to our terms. Provide information about our products and services. Solicit feedback about our products and services. Engage customers in surveys and contests. Provide relevant website content and advertising to customers, and measure or understand the effectiveness of the advertising we serve	Legitimate Interests: Providing products and services to our customers Providing our psychological assessment to personnel of our customers Reviewing email, phone, and other communications and activities related to your account to research how customers use our products and services. Keeping our records up to date. For good governance, accounting, management, and auditing of our business operations Sending you marketing activity information and product introductions Expanding our business and providing information for our marketing strategy Conducting research and product development to improve our products and services to serve our customers
Customer Manage contracts, invoices, payments, and expenses	Performance of the contract with the customer
Prospective Customers Contact prospective customers to determine their interest in our products and services.	Legitimate Interest: Send marketing materials and product information to potential corporate customers to determine their interest in our products and services.
Respondents Registration of respondents Complete our questionnaire.	Legitimate interests: Provide our psychological assessment and related products to personnel of our clients. Provide assessment or development center services by our professional services team. For good governance, accounting, management, and auditing of our business operations Keep our records updated. Conduct research and product development to improve our products and services, serving our clients. Agree: Regarding the processing of optional special category data, conduct research and product development to develop and improve our products and services.
Suppliers and other third parties Supplier registration and relationship management	Legitimate interests: To receive services to conduct our business and provide products and services to customers. To expand our business and provide information for our marketing strategies. To govern, account, manage, and audit our business operations effectively. To access emails, telephone calls, and other communications and activities related to your account. To maintain our records up to date
Suppliers and other third parties Manage payments, contracts, and expenses	Contract fulfillment with suppliers and other third parties
Survey participants Conduct surveys for research and product development purposes	Agree to: Process personal data and optional special category data for research and product development purposes, to develop and improve our products and services
Employees Provide employment to employees and manage employer/employee relationships	Comply with employee contracts (usually involving personal data) and respect the employer's legal rights (involving special category data), as further explained in the employee privacy statement
Recruiting Candidates Potential employment opportunities	Legitimate Interests: Provide employment opportunities
General situations: Manage and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting, and data hosting)	Legitimate interests: To make our business run, provide administrative and IT services, and network security
General situations: Use data analysis to improve our website, products/services, marketing, customer relationships, and experience	Legitimate interests: Define the customer types for our products and services. Keep our website updated and relevant, develop our business, and provide information for our marketing strategies

5. Who we transfer your personal data to

This section explains who we may share your data with, including cases where we transfer data to third parties for processing.

5.1 We may need to share your personal data with third parties for processing or sub-processing. We go through a selection process and regular reviews to determine processors and sub-processors. We may also share your personal data with controllers. Typically, our clients are controllers of client personal data and respondent personal data. Our clients may be practitioners or organizations, as described in section 5.2.3. We enter into data processing agreements with processors and controllers, as applicable.

5.2 We share your personal data with third parties for the following purposes:

5.2.1 Group affiliates (as processors):

• Other companies in our company group, including Sino Associates Global Limited in Hong Kong and Sino Associates Shanghai Consulting Limited in Shanghai, providing resources related to our professional learning and measurement assessment services, personnel recruitment, and internal IT functions; (ii) signing contracts for shared IT and system management services; and (iii) fulfilling internal reporting requirements.

5.2.2 Third parties (as processors):

• U.S., EU, and China-based vendors and partners providing IT, database, and system management services, as well as suppliers for website, logistics, event organization, video conferencing facilities, and other technology or services related to the services we provide to you.
• Licensors in the U.S. and EU for scoring and report generation of our psychometric assessments
• Partners representing us in providing training services in Europe, North America, ASEAN, and the Middle East
• Inquirers requiring information about practitioners' certification to use our measurement tool products.
• Potential acquirers where our business or business assets may be transferred.
• Law enforcement or regulatory agencies where we believe it necessary to comply with legal or regulatory obligations, or to protect Sino Associates Consulting Limited and its affiliates, our clients or their clients, or public safety, or to enforce or apply our business terms or other agreements.

5.2.3 Third parties (as controllers):

• When a respondent completes one of our psychometric assessments under the guidance of a practitioner, we share the respondent's results with the practitioner so that they can provide appropriate feedback to the respondent; practitioners may also share results or summaries with another practitioner in the same organization employing the respondent, as well as with the applicable employing organization.
• When respondent data is shared with our professional services team operating the assessment, development center, and/or consulting projects, personal data may be shared with practitioners in our professional services team and another practitioner in the same organization employing the respondent (if applicable), as well as with the applicable employing organization.
• When respondent data is merged with other respondent data, such as for team report purposes, this may be shared similarly.
• Inquirers requiring certification information about practitioners (including employing organizations of practitioners)
• Print suppliers for printed reports and learning manuals, with data being supervised for printing by our employees holding mobile hard drives without saving to the counterpart's computer.

5.3 We require all third-party suppliers to respect the security of your personal data and to process it in accordance with the law. We do not allow our suppliers to use your data for their own purposes and require their processing to be in accordance with our instructions.

6. International Transfer of Personal Data

This section explains where we transfer data internationally.

6.1 As described in section 5, we share your personal data with third parties, some of which may be located internationally, including:

• Certified practitioners for service and measurement products located in North America, the UK, ASEAN, the EU, and the Middle East
• Suppliers providing IT, database, and system management services to us, headquartered in the U.S. and elsewhere.

6.2 Data transferred includes:

• Customer contact data - SAP and Sales Force
• Respondent information provided by individuals assigned by client organizations when client organizations need to use measurement tools - certified practitioners of measurement tools such as (MBTI) The Myers-Briggs Company Limited, (DiSC) John Wiley & Sons, Inc. (IDI) IDI, LLC, (LDF) Harthill Consulting Limited, (CSI)Sino Associates Global Limited, (EES & EEPS) Sino Associates Global Limited, (LF360o) Sino Associates Global Limited, etc.

7. How We Protect Your Data

This section explains how we protect your data (section 7.1). It also explains how you can protect your own data by not sharing your username and password with others (section 7.3). It also explains that third-party sites linked to through our website are not covered by this privacy policy (section 7.4).

This section explains how we protect your data (section 7.1). It also explains how you can protect your own data by not sharing your username and password with others (section 7.3). It also explains that third-party sites linked to through our website are not covered by this privacy policy (section 7.4).

7.2 In addition, our employees, collaborators, and consultants are bound by confidentiality agreements and privacy statements, and in addition to mandatory privacy and data protection training, we have various policies specifically addressing responsibilities and expected behaviors for protecting confidential information.

7.3 We have incident and breach investigation and notification procedures. If we conclude based on a risk assessment of the individuals involved that a breach of personal data may result in a risk to individual rights and freedoms, we will immediately notify the individual (and the relevant controller and supervisory authority, as required by law) and notify in accordance with any contractual terms.

7.4 You should be aware that if we provide (or you choose) a username and/or password to enable you to access certain parts of our website or use our products and services, you are responsible for maintaining the confidentiality of your username and password. You should not share this information with anyone.

7.5 This privacy policy applies only to information collected by Sino Associates Consulting Limited and its affiliate entities. Third-party sites, plugins, and applications linked to through our website are not covered by this privacy policy. If you link to other websites, please read their personal privacy policies. We are not responsible for these policies or for any liability arising from them.

8. Data Retention and Anonymization

This section explains how long we retain data (section 8.1), including specific information on respondent data retention periods (section 8.2), and cases where we may anonymize data and retain it in aggregated form (section 8.3).

8.1 We only retain your personal data for as long as necessary to fulfill the purposes we collected the data for, including meeting any legal, accounting, or reporting requirements. Our internal data retention and destruction policy sets out how long we keep the data we collect.

8.2 Respondent data is typically retained for up to 24 months after the completion of the assessment or until the end of the project, whichever comes later. Depending on the specific project or service, respondent data may be retained for a longer period, subject to specific consent and legal or regulatory requirements.

8.3 Any retained research data from respondents (to generate statistical data described in our technical product manual, such as psychological measurement standards and efficacy data), as well as data from any surveys, no longer constitute personal data as they have been anonymized and aggregated prior to being used for research and product development purposes. This aggregated data is used for research and product development to improve our products and services, as well as for marketing, developing, improving our products and services, and strategic or other research purposes. This aggregated data is derived from your personal data but does not represent personal data as it has been aggregated and anonymized, so that no one can be identified or identifiable from this data. Aggregated data may be used indefinitely without further notice to you.

8.3 Any retained research data from respondents (to generate statistical data described in our technical product manual, such as psychological measurement standards and efficacy data), as well as data from any surveys, no longer constitute personal data as they have been anonymized and aggregated prior to being used for research and product development purposes. This aggregated data is used for research and product development to improve our products and services, as well as for marketing, developing, improving our products and services, and strategic or other research purposes. This aggregated data is derived from your personal data but does not represent personal data as it has been aggregated and anonymized, so that no one can be identified or identifiable from this data. Aggregated data may be used indefinitely without further notice to you.

9. Your Legal Rights

This section explains your legal rights regarding your personal data held by us, including your rights to:

• Access your data.
• Request correction of your data
• Request deletion and destruction of your data
• Object to our processing of your data
• Request transfer of your data to a third party
• Withdraw consent for data processing.

It also explains how you can choose to opt-out of direct communication and outlines the consequences of doing so.

You have the right to:

• Request access to your personal data (commonly known as a "subject access request" or "SAR"). This enables you to receive a copy of your personal data held by us and to check that we are lawfully processing it. We have a subject access request policy which outlines briefly how we handle subject access requests.
• Request correction of your personal data held by us. This enables you to correct any incomplete or inaccurate data held by us, although we may need to verify the accuracy of the new data you provide to us.
• Request deletion and destruction of your personal data. This enables you to request us to delete or destroy personal data. Data that has been deleted or destroyed cannot be restored. We may not always be able to comply with your deletion request due to specific legal reasons, which we will notify you of, if applicable, at the time of your request. However, we will comply with your request if you have successfully exercised your right to object to processing (see below), if we have unlawfully processed your information, or if we need to delete your personal data to comply with local laws.
• Object to our processing of your personal data. If you believe it impacts your fundamental rights and freedoms, you can object to our processing of your data, even if we rely on legitimate interests (or those of a third party) and based on your specific circumstances for data processing. You also have the right to object to our processing of your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
• Request restriction of our processing of your personal data. You can request us to suspend processing your personal data in the following scenarios: (a) if you want us to determine the accuracy of the data; (b) where our use of the data is unlawful, but you do not want us to delete it; (c) where you need us to retain the data (even if we no longer require it) as you need it to establish, exercise or defend legal rights; or (d) you have objected to our use of your data, but we need to verify whether we have overriding legitimate grounds to use it.
• Request transfer of your personal data to you or a third party. We will provide you or the third party you have chosen with your personal data in a structured, commonly used, machine-readable format. Please note that this right only applies to automated information that you initially provided consent for us to use, or where we used the information to perform a contract with you.
• Withdraw consent. If we rely on "consent" as a legal basis for processing your personal data, you can withdraw consent at any time. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. If this is the case, we will notify you when you withdraw your consent.

If we are the processor of your personal data, we will notify the relevant controller of your request and assist and cooperate with the controller in fulfilling the request.

When your client organization, who hired you, uses our measurement tools and products, you agree and acknowledge that you have assigned the processing and communication rights of the data to the contact person appointed by your organization in writing, who will communicate with us and handle changes, deletions, transfers, and other operations related to your measurement data.

9.2 No Charge

You do not have to pay any fees to access your personal data (or exercise any other rights). However, if the request is clearly unfounded, repetitive or excessive, we may charge a reasonable fee. Alternatively, in certain circumstances, we may refuse to comply with your request.

9.3 Further Information

We may need to ask you for specific information to help us confirm your identity or verify your right to access your personal data (or exercise any other rights). This is a security measure to ensure that personal data is not disclosed to anyone who is not entitled to receive it.

10. Updating Your Personal Data

This section explains what you should do if any data you provided to us changes.

The accuracy and timeliness of your personal data is important to us. To ensure this, please inform us of any changes to the personal data we hold about you at any time.

When your client organization employs our measurement tools and products, you agree and acknowledge that the processing and communication rights of the data are assigned to the contact person appointed by your organization in writing, who will communicate with us and handle your measurement data change operations.

11. How You Can Access the Personal Data We Hold

This section explains your right to access information we hold about you and the process for doing so.

If you wish to request access to the personal data we hold about you, please make a request to our Data Protection Officer in writing or by email - for details on how to contact us, see section 12.

12. How to Contact Us and Your Complaints Rights

This section explains how to contact us if you have any queries about data protection or privacy matters. It also tells you who to contact if you have a complaint about how Sino Associates Management Co., Ltd. handles data protection and privacy matters.

If you have any questions about this privacy policy or data protection or privacy matters, please contact us:

Email: dataprivacy@sino-associates.com

While we hope you won't need to, if you do wish to complain about how we handle personal data, you can contact us using the above contact details.

13. Governing Law

This section explains the governing law applicable to this Privacy Policy and any changes made to it in accordance with local law applicable.

This Privacy Policy is governed by Chinese law, and the place of performance of obligations will be in China.

14. Status and Changes of this Privacy Policy

This section explains when this privacy policy comes into effect, and our right to change it at any time.

This revised version of the privacy policy comes into effect on September 12, 2018, and we may change it at any time. Please check regularly and keep up with the updates.

15. Glossary of Terms

This section explains the meaning of certain terms used in the privacy policy.

Personal Data means any information related to an identified or identifiable natural person (data subject); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier, or one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person. European Personal Data means personal data of European data subjects.

Special Categories of Data means personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, genetic data, biometric data, data concerning health or sex life or sexual orientation. Controller means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data.

Processor means a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller.

Processing means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

Legitimate Interests mean the interests of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We ensure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).

Performance of Contract means processing your data is necessary for us to perform a contract with you or to take steps at your request prior to entering into such a contract.

Compliance with Legal or Regulatory Obligations means processing your personal data is necessary for compliance with a legal or regulatory obligation we are subject to.

Customer means an organization or individual who has signed a product and service agreement with Shenzhen Sino Enterprise Management Consulting and its affiliated companies.

Practitioners mean individuals who have registered with Sino Associates Consulting Limited and are qualified to administer one or more of our psychological measurement assessments, interpret the resulting reports from the respondents' answers, and provide feedback to the respondents.

Respondents mean individuals and relevant organizations who have or will undergo one or more of our psychological measurement assessments through Practitioners.

16. Appendix: Explanation of Demographic Data

Why do we ask demographic questions in our survey?

1. Background

Our survey requires respondents to answer certain questions before completing the survey, including both mandatory and optional questions.

As for the optional questions, they provide us with information that we use in our research and development activities. Answering these questions is a choice, but providing the information is very helpful to our research and development activities. It helps to improve the effectiveness of the survey in setting standards and in our commitment to diversity, equity, and inclusion.

2. Effectiveness and Inclusion

Historically, researchers in various fields have failed to include everyone when sampling populations. When a sample lacks inclusion, it can lead to erroneous conclusions and incorrect generalizations of people not included in the study sample.

Sino Associates Consulting Limited is committed to ensuring that our measurements meet the highest psychological measurement standards and strives to include and evaluate people of different genders, races, and cultural backgrounds. To do this, and in line with the recommendations of major research institutions, we therefore ask various demographic or biometric data questions so that we can accurately describe the composition of the normative group and representative sample, as well as summarize the sample used for ongoing research.

Guidance from Psychological Associations

The decision to do this is based on recommendations from the Chinese Psychological Association, the American Psychological Association, and the British Psychological Association on the guidelines of the International Testing Committee. Some of these guidelines include the following comments:

American Psychological Association https://www.apa.org/ethics/code/ 3.01 Unfair discrimination in its work-related activities, Psychologists do not engage in unfair discrimination based on age, gender, gender identity, race, ethnicity, culture, national origin, religion, sexual orientation, disability, socioeconomic status, or any legally prohibited basis in their work-related activities. Psychologists who develop tests and other assessment techniques use appropriate psychometric procedures and current scientific or professional knowledge for test design, standardization, validation, reduction or elimination of bias (with emphasis), and recommendations for use.

APA GUIDELINES on Race and Ethnicity in Psychology https://www.apa.org/about/policy/guidelines-race-ethnicity.pdf Guidelines: Principle 1: Psychologists strive to recognize and understand the role of race and ethnicity in all aspects of professional activity, as an ongoing process. Practice: Principle 9: Psychologists strive to provide assessments, interventions, and consultations that are free from negative effects of racial and ethnic cultural bias. Research: Principle 13: Psychologists are encouraged to recognize the important role of science in informing practice and policy, and therefore strive to conduct and disseminate research that promotes the well-being of racial and ethnic minorities. Principle 14: Psychologists strive to identify and reduce the negative effects of racial and ethnic cultural bias in research methods, analysis, and interpretation of results. Specifically, psychologists are encouraged to recognize the impact of internal validity on external validity when generalizing research to racial and ethnic cultural groups. Therefore, the aim of psychologists is to address external validity issues and clearly identify to which populations their research results apply (D.W. Sue, 2017; S. Sue, 1999). For example, psychologists are encouraged to always describe their human samples. If psychologists' samples are primarily composed of European American white participants, they are encouraged to state this explicitly and describe the limitations of generalizability to racial and ethnic cultural groups. Additionally, psychologists are encouraged to increase methodological rigor and better address external validity issues by diversifying their study samples. Principle 15: Psychologists' goal is to operationally define race, ethnicity, and related constructs in research. Principle 16: Psychologists' goal is to maintain ethical standards with a racial and ethnic cultural response when conducting research. Principle 17: Psychologists strive to promote practices that ensure racial and ethnic equality in research systems.

These guidelines require us to understand the ethnic and racial composition of our samples for ongoing research in our psychological assessments.

APA Style and Grammar Guidelines, Bias-Free Language, Gender https://apastyle.apa.org/style-grammar-guidelines/bias-free-language/gender Gender Reporting: authors are strongly encouraged to explicitly specify information about participants' gender identity (e.g., whether participants are transgender, cisgender, or another gender identity) that makes up the sample, rather than assuming cisgender identity. British Psychological Society and International Testing Committee guidelines on testing use: 2.3. Consider fairness issues in testing. When tests are used with individuals from different groups (e.g., groups with differences in gender, cultural background, education, racial origin, or age), competent test users will make every reasonable effort to ensure that: 2.3.1. The test is unbiased and appropriate for the various groups being tested.

3. Conclusion

Optional demographic or biological data items regarding race or ethnicity, gender, and age enable us to ensure that we are following the inclusive and unbiased guidance provided by various organizations. These items allow us to demonstrate the effectiveness of our tools across a broad range of individuals and help ensure the fairness of the interpretation and use of assessment results.

For more information on this or our research and evaluation issues, please contact dataprivacy@sino-associates.com.

Revised by Sino Associates Consulting Limited in October 2021.