Effective Date:  Jan 1, 2025

PRIVACY POLICY

This Privacy Policy describes the types of information Tong Fang Capital Management LLC, and their affiliates (“Tong Fang”) collect from you when you visit or access www.tongfangcapital.com or any other of our websites where this policy is posted or otherwise interact with us online. It applies to every person who visits, accesses, or registers with the Platforms (including any future Apps we may develop), applies for a job with us, receives newsletters or other marketing communications issued by or on behalf of Tong Fang, or engages with us to use the services that Tong Fang provides (collectively the “Services”) except as otherwise contractually agreed.

This Privacy Policy also explains how Tong Fang may use and disclose your information and how you may control certain uses of your personal data.  This Privacy Policy is in addition to any separate annual privacy policy or notice that Tong Fang may send individuals who participate certain Services that Tong Fang offers.

Please note that the data controller (or similar term under local law) is generally the Tong Fang entity you contract with in relation to our Services or the Tong Fang entity to which you apply for a job.  However, Tong Fang is an international business, and your personal data may be processed by other Tong Fang group companies or companies managed by Tong Fang on a joint data controller basis, where permitted by applicable law.  “Personal data” and “information” are used interchangeably throughout this Privacy Policy and each refer to information about identifiable natural people.

INFORMATION COLLECTION

Information Collected About Clients and Visitors to Our Platforms

We collect information from you when you choose to share it with us, when you visit or access our Platforms, request information from us, or contact us.

The information we collect from you may include:

  • Contact information, including your name, address, email address, or phone number;

  • Employer-related information, such as your title and the company’s name, address, and phone number;

  • Profile data, such as your account username and password for our Platforms;

  • Location information (IP address, IP address locations, information about your location);

  • Platforms activity (how you use our Platforms, pages viewed, time of service, date of service, duration of service, time since last visit, links clicked, information about pages viewed on our Platforms);

  • Off-Platforms activity (referring website addresses, information about the site or app you came from);

  • Information about your device (device type, internet connection type, linking multiple devices to the same user) and browser (like type and language); and

  • Marketing and communications data, such as marketing or communication preferences.

Information Collected about Participants in One of Our Programs

We may collect information that you provide to us directly, that we receive from third parties, or that we collect automatically as you access any of our Platforms in connection with your participation in one of our programs.  In addition to the types of information that may be collected about visitors to our Platforms, we may collect information you provide during the on-boarding process, including information provided on your tax forms, authorization agreement for direct deposits, personal data collection form, and supplemental disclosures.

Information Collected about Prospective Employees and Job Applicants

We may collect the following information about you that you either provide to us directly, that we receive from third parties, or that we collect automatically as you access any of our Platforms.  In addition to the types of information that may be collected about visitors to our Platforms, we may collect:

  • Career demographics (job title, role, profession, education, industry, years of experience, skills);

  • Career interests (career topics and areas of interest, expected date of graduation for current students, majors, locations interested in working, interests in upcoming events);

  • Information you provided in-person (e.g., at events attended);

  • Topics you have expressed interest in;

  • Email activity (emails opened, email program used, clicks in email);

  • Profile information from social media sites;

  • Information you submit to us (e.g., submitted images, photos, videos; other items you submit; details about your requests made to us); and

  • Job(s) applied for or interested in (including the job opening’s education and experience description).

Information Collected from Third Parties or Other Sources

We may obtain personal or other information about you from third parties or other sources and combine this information with the information we collect from you.  This might include any other information obtained through companies that have business relationships with us, such as our licensees, affiliates, and business partners.

We may also obtain information about you from other online sources, including when you connect with Tong Fang through its official corporate pages on third-party social networks (such as LinkedIn or Facebook) or other apps.  This information may include your name, user name, demographic information, updated address or contact information, interests, and publicly-observed data.  We may combine this information with the information we collect from you through the Platforms.

For prospective employees and job applicants, in addition, we may obtain information about you from third parties, including without limitation, recruitment agencies, background check providers, credit reference agencies, and your references, where required or permitted to conduct such checks under applicable law.

Information Automatically Collected through Cookies

We may use cookies, web beacons, pixel tags, JavaScript, or other similar technologies (which we generically refer to as “Cookies”) to collect certain information about visitors to our Platforms and interactions with our emails and online or mobile advertisements, and to allow Tong Fang to keep track of analytics and statistical information that enables us to improve our Platforms and provide you with more relevant content on our Platforms and marketing channels.

For example, we may collect information about your use of the Platforms, including the Platforms activity and off-Platforms activity described in the Information Collected About Clients and Visitors to Our Platforms section; emails that you open, forward, or click-through to our Platforms; comments and ratings you submit; and website and/or app preferences and settings.

We may also use third-party Cookies to support our Platforms, provide services on our behalf, complete business transactions, or provide relevant advertising to you.  Some of these third parties may use Cookies on our Platforms, which may send them some of the above-referenced information.  The use of this information by those third parties will be governed by their own privacy policies including, for example, Google’s Analytics Privacy Policy or the Salesforce Privacy Policy.

We also may use Cookies to collect information about your online activities over time and across third-party websites, apps, or other online services (behavioral tracking).  If you click on or otherwise interact with an advertisement, we may assume that you meet the target criteria.

Management of Cookies, Tracking Options, and Do Not Track Disclosures

There are various ways that you can manage your Cookie preferences, but please be aware that in order to use some parts of our Platform you will need to allow certain essential or functional Cookies. If you block or subsequently delete those Cookies, some aspects of our Platform may not work properly, and you may not be able to access all or part of our Platform.

For further information about types of Cookies used and to customize your cookie preferences please visit Manage My Preferences.

Additionally, you are free to set your browser or operating system settings to limit certain tracking or to decline Cookies, but by doing so, you may not be able to use certain features on the Platforms.  Refer to your Web browser’s or operating system’s website or “Help” section for more information on how to delete and/or disable your browser or operating system from receiving Cookies and how to control your tracking preferences.

On your mobile device, you may also adjust your privacy and advertising settings to control whether you want to receive more relevant advertising.

PURPOSE FOR PERSONAL DATA COLLECTION, USE, AND DISCLOSURE

Tong Fang may collect, use, and disclose your personal data for any of the following purposes:

  • To deliver’s Tong Fang’s Services to you;

  • For your participation in certain of our programs;

  • To enhance your online experience, including as a way to recognize you and welcome you to the Platforms;

  • To develop new products or Services and to conduct analysis to enhance current products and Services;

  • To review the usage and operations of our Platforms and improve our content, products, and Services;

  • To recognize your online activities over time and across different websites, apps, and devices;

  • With your express opt-in consent where required, to provide you with customized content on our Platforms or via email, telephone, text message, mail, or other marketing channels;

  • With your express opt-in consent where required, to contact you with information, newsletters, and promotional materials from Tong Fang or on behalf of our business partners, licensees, and affiliates;

  • With your express opt-in consent where required, to serve ads through third-party services (including social media platforms) that are targeted to reach people on those services who are identified in our databases.  This may be done by matching common factors between our databases and the databases of third-party operators.  For example, we may use LinkedIn Custom Audiences to provide such information on LinkedIn to people whose information and email addresses we already have and who expressed an interest in hearing from us;

  • For recruiting, position advertising, talent management, and employment purposes, including assessment, selection, or conclusion of an employment offer, inclusion in our recruitment database for possible future employment opportunities (with your consent where required), and to comply with our legal and regulatory obligations in relation to recruitment;

  • To contact you when necessary by email, phone, text message, mail, or in-app direct message;

  • To use your data in an aggregated, anonymous, non-specific format for analytical purposes;

  • To address problems with the Services or our business;

  • To protect the security or integrity of the Platforms and our business, such as by protecting against and preventing fraud, unauthorized transactions, claims, and other liabilities and by managing risk exposure, including by identifying potential malicious or unauthorized users or uses; and

  • As otherwise described to you at the point of data collection.

Personal data will only be collected for the purpose outlined above and not further processed in a manner incompatible with those purposes.

Additionally, if you use the Platforms to connect with third-party services you authorize us to use information from you, on your behalf, to interact with these third-party services based on your requests.

LINKS TO OTHER WEBSITES

The Platforms and email messages from us may contain links to third-party websites, which may have privacy policies that differ from our own.  You should be aware that the collection, retention, and use of any data you provide on these websites will be governed by the privacy policy of the company providing the website and not by this Privacy Policy.  We are not responsible for the practices of such websites.

CHILDREN’S PRIVACY

Protecting children’s privacy is important to us.  We do not direct the Platforms to, nor do we knowingly collect, any personal data from children under the age of eighteen.  If we learn that a child under the age of eighteen has provided personal data to the Platforms, we will use reasonable efforts to remove such information from our files.

DATA SECURITY

We have taken reasonable physical, administrative, and technical steps to safeguard the information we collect from and about our customers and Platforms visitors to prevent unauthorized access, collection, use, disclosure, copying, modification, leakage, loss, damage, and/or alteration of your personal data.

DATA STORAGE

Your personal data may be stored on servers in the United States and be subject to the laws of the United States, where the data protection and other laws may differ from those of other countries, or on servers in other countries when necessary for one of the reasons set forth above or to deliver the Services.  Your personal data may be disclosed in response to inquiries or requests from government authorities or to respond to judicial process in the countries in which we operate.

YOUR OPTIONS AND ACCESS TO YOUR PERSONAL DATA

You may have other rights in your jurisdiction to know whether we process your personal data; to obtain a copy of your personal data; to correct any inaccuracies in the personal data we maintain about you (taking into account the nature of the personal data and the purposes for processing such personal data); to request we delete your personal data; and to opt-out of certain personal data processing by Tong Fang.  You may contact your account representative to update your information in our system.  If you have any additional questions concerning access to or updating your personal data, as well as to exercise any other rights you may have in your jurisdiction, please contact us at the information provided in the “Contact Us” section below. You will not face any retaliation or discrimination for exercising your rights. We take reasonable steps to ensure that any personal data we collect, disclose, and use is accurate and complete, especially if your personal data is likely to be used by us to make a decision that affects you or disclosed to a third party. However, it is important that you advise us of any changes to your personal data or if there are any errors in the personal data we hold about you. We will not be responsible for relying on inaccurate or incomplete personal data arising from your not updating us regarding changes in your personal data that you had initially provided us with.

COMPLAINTS

If you believe that we have not complied with this Privacy Policy or you have any grievances in relation to our collection, use, and disclosure of your personal data, you may submit a complaint to us using the information provided in the “Contact Us” section below. Where you consider that our response to your complaint is inadequate, you may escalate your complaint to the Regulator in your respective jurisdiction, whose contact details are provided in the “Our Companies, Offices, Locations, and Regulators” section above.

CONTACT US

We hope this Privacy Policy answers your questions about our collection, use, and disclosure of your personal data.  If you have additional questions about this Privacy Policy or the practices described here, you may contact us via the Contact Us page.

REVISIONS TO THIS PRIVACY POLICY

Tong Fang reserves the right, at its sole discretion, to change, modify, add, remove, or otherwise revise portions of this Privacy Policy at any time to reflect any changes or proposed changes to our use of your personal data, or to comply with changes in applicable law or regulatory requirements.  If we do, we will update the effective date at the top of the page.  Your continued use of the Platforms following the posting of changes to these terms means you accept these changes.

Non-affiliated third parties are independent from Tong Fang. If you wish to receive information about your disclosure choices or stop communications from such third parties, you will need to contact those non-affiliated third parties directly.