Last updated on October 20, 2020

This Privacy Policy describes how Thinkingdom Media Group Limited and its parents, subsidiaries, affiliates, and successors and assigns (collectively “Thinkingdom”, “we”, “us”, or “our”) collects and processes your personal information through our websites, social media pages, sweepstakes and other promotions, programs and events, newsletters, and any other services we may provide (collectively the “Services”). By using the Services, you accept the terms of this Privacy Policy.

What Personal Information Do We Collect?

How Do We Use Personal Information?

Do We Share Personal Information?

How is Personal Information Stored?

How is Personal Information Processed, Transferred and Protected?

Notices and Revisions

Contacting Us

What Personal Information Do We Collect?

Information You Provide to Us

We collect personal information that you volunteer to us when you use our Services.

Examples of personal information you might supply us include:

●    identifying information such as your name, address, email address, and phone number
●    your age
●    your location information
●    information to confirm your eligibility for contests, promotions, and sweepstakes
●    personal descriptions included in your profile
●    information and documents regarding identity

Automatic Information

We also automatically collect and store certain types of information about your use of our websites, including information about your interaction with content and services available through us.

Examples of automatic information we may collect includes:

●    the internet protocol (IP) address used to connect your computer to the internet
●    the location of your device or computer
●    browser type and version
●    operating system
●    version and time zone settings
●    the full Uniform Resource Locator (URL) clickstream to, through, and from our websites, including date and time; products and content you viewed or searched for; page response times, download errors, length of visits to certain pages, and page interaction information (such as scrolling, clicks, and mouse-overs)

Information We Receive from Others

We also may receive information about you from third parties who operate services we use in order to provide our services to you. For example, we work with third parties regarding technical services, advertising networks, and search information providers. We may receive email addresses, mailing addresses, and demographic information from these third parties.

Use of Cookies and Pixels

Like many websites, we use "cookies" and other unique identifiers, and we obtain certain types of information when your web browser or device accesses our websites. By using our websites, you consent to our use of such cookies in accordance with this policy.

A cookie is a very small text document, which often includes an anonymous unique identifier. When you visit a website, that site’s computer asks your computer for permission to store this file in a part of your hard drive specifically designated for cookies. Each website can send its own cookie to your browser if your browser’s preferences allow it, but to protect your privacy your browser only permits a website to access the cookies it has already sent to you, not the cookies sent to you by other sites.

We reserve the right to use cookies and their technological equivalents, including social media pixels. We reserve the right to use these pixels in compliance with the policies of the various social media sites.

You may block our use of cookies through the settings on your browser. However, in order to use some of our Services on your web browser must accept cookies. If you choose to block the use of cookies, certain aspects of our Services may not work properly and you may not be able to access or use all of the features and services we provide.

How Do We Use Personal Information?

We use information you provide to us to manage our contractual relationship with you, provide our services, to improve our performance and fix any errors, communicate with you, provide you with information, to prevent and detect fraud and abuse, to comply with our legal obligations, or based on our legitimate interests.

Do We Share Personal Information?

Your personal information is important to us, and so we only share in the ways described below.

We may disclose personal information to third-party providers who perform certain functions on our behalf. Examples include transmitting content and providing customer service. These third-party service providers have access to personal information needed to perform their func-tions, but may not use it for other purposes.

We may disclose your personal information to a third party, including a lawyer or collection agency, when necessary to enforce our terms and conditions.

We may disclose information when we believe such release is appropriate to comply with the law, or to protect our and our users’ rights and safety.

How is Personal Information Stored?

The security of your personal information is important to us. We use reasonable and appropriate measure to protect this information from loss, misuse, and unauthorized access, disclosure, alteration and destruction, taking into due account the risks involved in the processing under-taken and the nature of the personal information we collect.

We will keep your personal data for as long as we need it, or as otherwise prescribed by law, for the purposes set out above. This period will vary depending on your interactions with us. We may also keep a record of correspondence with you (for example if you have made a complaint) for as long as is necessary to protect us from a legal claim.

How is Personal Information Processed, Transferred and Protected?

Purpose and Legal Basis for Processing Your Personal Information

The purpose and legal basis for processing your personal information will typically be one of the following:

●    our own legitimate business interests, provided they don’t outweigh your rights or freedoms
●    the performance of a contract that we have in place with you
●    your consent where appropriate
●    compliance with our legal obligations, including to meet national security or law enforcement requirements

We may disclose your personal information to related companies and third parties as described in this Privacy Policy; however, we do not authorize third parties to market their products or services to you without having obtained your prior consent. If you give consent for such shar-ing, you may revoke it any time.

We do not knowingly collect personal information from children under the age of thirteen (13).

Data Retention

We will retain the any information you choose to provide to us until the earlier of: (a) you asking us to delete the information, (b) our decision to cease using our existing data providers, or (c) we decide that the value in retaining the data is outweighed by the costs of retaining it.

International Transfer

Thinkingdom is based in China. Your personal information may be processed or stored in China and other countries which may not have equivalent privacy or data protection laws. By using our Services, you consent to these transfers and hereby agree that you will not make any claims against us arising out of, in connection with, or otherwise relating to these transfers.

Your Rights

You have the right to request access to your data that we store and the rights to either rectify or erase your personal data.

You have the right to seek restrictions on the processing of your data.

You have the right to object to the processing of your data and the right to the portability of your data.

To the extent that you provided consent to our processing of your personal data, you have the right to withdraw that consent at any time, without affecting the lawfulness of processing based upon consent that occurred prior to your withdrawal of consent.

To exercise these rights please email us at

Notices and Revisions

If you choose to use our Services, your use and any dispute over privacy is subject to this Privacy Policy, including limitations on damages, resolution of disputes, and application of the law of the People’s Republic of China. If you have any concern about the privacy of our Services, please contact us with a thorough description, and we will try to resolve it.

Contacting Us

If you have any questions or suggestions with respect to this Privacy Policy or our privacy practices, please email us at