Privacy Policy

Data protection and privacy guidelines

Titan Investment Group Holdings LLC, DBA Titan Network, operates chinamagictrip.com and titannetwork.com. Titan Network and all of its entities respect individual privacy and value the confidence of our members, customers, employees, vendors, consumers, business partners and others. We collect, store, process and distribute personal information in a manner consistent with the laws of the countries in which we do business, and we hold ourselves to high ethical standards in how we handle that information.

This policy sets out the privacy principles Titan Network follows for the collection, use and transfer of personal information from anywhere in the world, including transfers from the European Economic Area, which includes the member states of the European Union plus Iceland, Liechtenstein and Norway. Titan Investment Group Holdings LLC has a Data Protection Officer who helps ensure compliance with this policy. Our Data Protection Officer is available to any member, employee, customer, vendor, business partner or other person with questions about this policy or our data security practices. Contact details are provided below.

Transfers of personal data

Titan Network and all of our entities rely on recognised legal mechanisms, including standard contractual clauses, as the basis for transferring personal data internationally, including from the European Economic Area. Titan Network is subject to the investigatory and enforcement powers of the Federal Trade Commission.

Scope of this policy

This policy applies to all personal information Titan Network receives in any format, including electronic, paper or verbal. We collect, store and process personal information about current and former employees, and applicants for employment, through our websites, our intranet, email and manual processes. We will not sell or share this information in ways different from what is disclosed in this policy, and we maintain business procedures consistent with this policy on a global basis.

We collect personal information from current and past members, such as name, contact information and financial account information, for purposes including administration, training and development, management planning, meeting governmental reporting requirements, security, health and safety management, performance management, network access, internal ethics administration, workplace communications, workforce analytics and authentication. We do not request or gather information about political opinions, religion, philosophy or sexual preference. Where we hold information on medical health, race or ethnicity, we protect and process it consistently with this policy and applicable law.

We also collect, store and process personal information from prospective customers, consumers, vendors, professional advisers, consultants, distributors, dealers, suppliers, business partners and others, such as name, contact information and financial or other payment information, for legitimate business reasons including processing and fulfilling orders, customer service, product and warranty administration, meeting governmental reporting and records requirements, marketing, internal marketing research, safety and performance management, and financial and sales data. We may process or disclose personal information to service providers, advisors, or potential transactional partners in connection with a corporate transaction such as a merger, acquisition or sale of assets, and where reasonably necessary or legally required, such as to respond to lawful requests from public authorities or to establish, exercise or defend legal claims.

Definitions

Agent means anyone that processes personal information provided by Titan Network to perform tasks on behalf of, or at the instruction of, Titan Network.

Titan Network means Titan Investment Group Holdings LLC and its subsidiaries, divisions and groups, including brands such as Titan Network, China Magic, Titan Integrator and Titan Ignite.

Personal information means any information that identifies, or could be used to identify, an individual. It does not include anonymised information, or publicly available information that has not been combined with non public personal information.

Sensitive personal information means personal information that reveals race, ethnic origin, trade union membership, political opinions, or religious or philosophical beliefs, or that concerns health, sex life or criminal records. We also treat as sensitive any personal information that is treated as sensitive at its source.

Privacy principles

Titan Network commits to the following principles for the personal information covered by this policy.

Notice. Where we collect personal information directly from individuals, we inform them about the purposes for which we collect, store and process it, the types of parties we disclose it to, and the choices and means we offer for limiting its use and disclosure. Notice is given in clear language when individuals are first asked to provide personal information, or as soon as practicable afterward, and always before we use the information for a purpose other than the one it was originally collected for.

Choice. We offer individuals the opportunity to opt out where their personal information would be used for a purpose other than the one it was originally collected for or subsequently authorised for. For sensitive personal information, we ask for affirmative, explicit consent before disclosing it to a non Agent or using it for a new purpose. We provide reasonable mechanisms for individuals to exercise these choices.

Data integrity and purpose limitation. We use personal information only in ways compatible with the purposes for which it was collected or subsequently authorised, and we take reasonable steps to keep it relevant, accurate, complete and current.

Accountability for onward transfer. We use Agents to help us support our customers, perform technical operations, and store and transmit data. We confirm that anyone we disclose personal information to will appropriately safeguard it, for example through a contract requiring at least the same level of protection as this policy, or because they are subject to EU data protection law or an equivalent adequacy finding. If we become aware that personal information is being used or disclosed contrary to this policy, we take reasonable steps to prevent or stop it.

Access and correction. On request, we grant individuals reasonable access to personal information we hold about them, and we take reasonable steps to let individuals correct, amend or delete information shown to be inaccurate or incomplete. Employees who want to review or update their personal information can contact their local Human Resources representative.

Security. We take reasonable precautions to protect personal information from loss, misuse and unauthorised access, disclosure, alteration and destruction. This includes physical security around equipment and records, and electronic measures such as firewalls, restricted access and encryption. Access to personal information is limited to those with a specific business purpose for it, and anyone with access is trained on their responsibility to protect its security, confidentiality and integrity. Suppliers, vendors, partners and Agents should report any actual or potential data breach to our Data Protection Officer.

Recourse, enforcement and liability. We conduct compliance audits of our relevant privacy practices to verify compliance with this policy. Any employee found to be in violation of this policy is subject to disciplinary action, up to and including termination of employment.

Dispute resolution

Questions or concerns about the use or disclosure of personal information should be directed to Titan Network's Data Protection and Privacy Office at the contact details given at the top of this policy. We investigate and attempt to resolve complaints and disputes in accordance with the principles in this policy. For complaints that cannot be resolved directly, Titan Network has agreed to participate in applicable dispute resolution procedures established by the relevant data protection authorities, and in some circumstances complainants may be able to appeal a decision through binding arbitration. These dispute resolution mechanisms are free of charge.

Cookies and tracking technologies

Chinamagictrip.com and titannetwork.com use tracking technologies such as cookies, web beacons and tracking scripts to collect and analyse information about how visitors interact with our websites. These technologies help us improve our services, provide a better user experience and offer more relevant content. We may use analytics and advertising scripts, such as Google Analytics and the Meta Pixel, to monitor how visitors use our site, including which pages they visit, how long they spend on them, and which links they click. This information is used for performance analysis, marketing and to provide more relevant content.

Our sites may contain links to other websites that Titan Network does not operate. We are not responsible for the content or privacy practices of those sites, and we encourage visitors to read the privacy statements of any site they visit, since their practices may differ from ours.

European Union: GDPR

This policy sets out the privacy principles Titan Network follows for personal information transferred to us from anywhere in the world, including transfers from the European Economic Area. If you are located in the EU or are a data subject protected by the GDPR, you can raise your rights under GDPR with the relevant Data Protection Officer responsible for your personal data.

Where you are not a job applicant, employee or former employee, our processing of your personal data may be based on the necessity of performing a contract with you, taking steps at your request before entering into a contract, a legal obligation, our legitimate interest, such as where you work for a supplier or customer whose data we need for normal business operations or where you browse our website, or your consent, such as where you have agreed to receive direct marketing.

Under the GDPR, individuals have the right to access the personal data we process about them, the right to rectification and erasure of their data, the right to obtain restriction of processing and to object to processing, the right to data portability, the right to withdraw consent at any time where processing is based on consent, and the right to lodge a complaint with the competent supervisory authority. These rights may be subject to conditions and exceptions under the GDPR. To exercise these rights, contact us in writing with your name, address and other relevant contact details at [email protected]. We may ask you to verify your identity and will use reasonable efforts to respond within the time limits set by applicable law.

Except where applicable law or regulatory requirements say otherwise, we retain personal data only for as long as necessary to fulfil the legitimate business purposes for which it was collected, including meeting legal, tax, accounting or other reporting obligations. Where destroying or erasing personal data is not legally required, we may anonymise it so that it can no longer be associated with or traced back to the individual.

California Consumer Privacy Act (CCPA)

We do not sell personal information as defined under the California Consumer Privacy Act. Titan Network is committed to complying with the CCPA, other applicable state privacy laws in the United States, and the GDPR for users in the European Union. California residents with questions about their rights under the CCPA can contact us at [email protected].

Changes to this policy

The practices described in this policy are current as of the effective date shown above. Titan Network reserves the right to modify or amend this policy at any time, consistent with the relevant principles and applicable law. Appropriate notice will be given for any such changes.