TRISTAR understands the importance of privacy to you and respects your privacy. Please read and understand this Privacy Policy (hereinafter referred to as "Policy") before submitting your personal data to TRISTAR. This Policy applies to Websites owned and operated by TRISTAR. This Policy describes the information practices of the TRISTAR Website, including what information is collected, how it is used, with whom it is shared, and how it is protected.

This Policy also explains how to process your personal data but may not cover all possible data processing scenarios. TRISTAR Websites may contain links to other Websites. TRISTAR is not responsible for the privacy practices or content of these Websites.

We have developed this Policy to help you understand the following contents:

1. How does TRISTAR collect and use your personal data

2. How does TRISTAR use cookies and similar technologies

3. How does TRISTAR disclose your personal data

4. How to access or modify your personal data

5. How does TRISTAR protect and retain your personal data

6. How does TRISTAR process children's personal data

7. Third party providers and their services

8. How your personal data is transferred globally

9. How to update this Policy

10. How to contact TRISTAR

1. How does TRISTAR collect and use your personal data

Personal data is information that identifies an individual when it is used alone or in combination with other information. Such data will be submitted directly to us when you use our Website, products, or services and interact with us. For example, these data are obtained when you create a TRISTAR account or contact us for support, or we record how you interact with our Websites, products, or services, such as cookies technology or receiving usage data from software running on your device. We will also obtain data from public and commercial third party sources as permitted by law. The data we collect depends on how you interact with TRISTAR, including the websites you visit and the products and services you use. This data can include your first name, last name, gender, company or organization name, job role, address, email address, telephone number, country or location, industry, login information (account number and password), photos, document information, etc. We also collect the information you provide to us and the content of the messages you send us, such as the query information you enter or the questions or device information you provide to receive customer support. You may be required to provide your personal data when using TRISTAR products or services. In some cases, you may choose not to provide personal data to TRISTAR, but if you choose not to provide it, TRISTAR may not be able to provide you with related products or services or respond to or solve your problems.

We may use your personal data for the following purposes:

(a) Create an account.

(b) Fulfill your transaction or service request, including executing orders; delivering, activating, or verifying products or services; providing training and certification and managing and processing training and certification results; participating in online or offline activities; changing or providing the information you request (such as marketing materials for products or services, white papers); and providing technical support.

(c) Contact you with your consent; send you information about products and services that may be of interest to you; invite you to participate in TRISTAR events, market research, or satisfaction surveys; or send you marketing messages. If you do not wish to receive such information, you can unsubscribe at any time.

(d) Send you important notifications, such as notifications for updating and installing operating systems or applications.

(e) Provide you with personalized user experience, advertising, and information content. In order to facilitate your access to advertising and information content that is more valuable to you, we provide you with personalized advertising and information content services that allow you to receive advertising and information content that may be of greater interest to you on our and our partner third party websites, applications, and other channels. Personalized ad recommendation technology is a common, general, safe technology to match your interests in ads moderately. We will strictly comply with the relevant provisions of laws and regulations, respect and protect your privacy. You can enable or disable this feature according to the third party platform rules.

(f) Authenticate and manage suppliers and business partners to communicate or conduct business with them.

(g) Conduct internal audits, data analysis, and research to improve our products and services.

(h) Analyze the efficiency of business operations and measure market share.

(i) Troubleshoot the error if you choose to send us the error details.

(j) Synchronize, share, and store the data you upload or download and perform uploading and downloading the desired data.

(k) Protect the safety of our products, services, and customers or users, implement and protect us from loss, and improve anti-fraud programs.

(l) Comply with and enforce applicable legal requirements, relevant industry standards, or our policies.

The TRISTAR may also collect and use Non-identifiable data. Non-identifiable data is data that cannot be used to determine an individual's identity. For example, TRISTAR collects summarized statistics, such as Website visits. The purpose of collecting these data is to understand how users use Websites, products, and services. This way, TRISTAR can improve its services and meet customer needs. TRISTAR may, at its discretion, collect, use, process, transfer, or disclose non-identifiable data for other purposes. We will do our best to isolate your personal from non-identifiable data and use them independently. If your personal data contains non-identifiable data, it will still be treated as personal data.

When TRISTAR processes your personal data, we will comply with applicable legal requirements based on appropriate legality, including:

● Process your personal data for the fulfillment of the contract in response to your transaction or service request;

● Process your personal data based on your consent;

● We will be based on the legitimate interests of us or third parties when your personal data are processed for the purpose of contacting with you, conducting marketing or market research, improving our products and services, and improving our loss prevention and implementing anti-fraud programs. These legitimate interests include: helping us manage and operate our business more effectively and provide our products and services; protecting the security of our businesses, systems, products, services, and customers; managing internally and complying with internal policies and processes; and other legal interests we describe in this Policy, etc.;

● We may also process your personal data based on compliance and enforcement of legal obligations.

2. How TRISTAR uses cookies and similar technologies

To keep our Website running, we sometimes store small data files called cookies on your computer or mobile device. A cookie is a plain text file that a web server stores it on a computer or mobile device. The content of a cookie can only be retrieved or read by the server that created it. Each cookie is unique to your web browser or mobile app. Cookies usually contain an identifier, a Website name, and some numbers and characters. With cookies, Websites can store data such as user preferences to better serve users. TRISTAR’s purpose of enabling cookies is the same as that of most Websites or Internet service providers, which is to improve the user experience. With cookies, Websites can store user's single visit (using a session cookie) or multiple visits (using a permanent cookie). With cookies, Websites can save settings such as the language, font size, and other browsing preferences of a computer or mobile device. This means that users do not have to reconfigure user preferences every time they visit. If a Website does not use cookies, the Website treats visitors as new visitors each time he/she opens a web page. For example, if you log in to one Website and go to another page, the Website will not recognize you, and you will be logged out again. TRISTAR will not use cookies for any purposes other than those stated in this Policy. You can manage or delete cookies based on your preferences. For more information on cookies, please see AboutCookies.org.

In addition, we may use local storage objects (LSOs) such as Flash cookies and HTML5 to store content information and preferences. We also work with our third-party partners so that our third-party partners may display ads on our websites and applications or manage our ads on other platforms and channels. Our third party partners may use cookies or similar technologies to provide ads based on your browsing activity and interests.

Various browsers may provide their own management tools to remove the HMTM5 LSO. You can clear all cookies saved on your computer, and most web browsers provide the function of blocking cookies. But if you will do this, you will need to change the user settings yourself each time you visit our Website. For more information on how to change your browser settings, please visit the following links:

Internet Explorer    Google Chrome    Mozilla Firefox    Safari    Opera

3. How does TRISTAR share, commission, and disclose your personal data

In the event that TRISTAR's authorized partners provide certain services, TRISTAR will share your personal data with these partners as described in this Policy. For example, when you buy TRISTAR products online, TRISTAR must share your personal data with the logistics service provider to make delivery or arrange a partner to provide the service. In addition, as an international company, we may share personal data in other language Websites of TRISTAR.

We may commission the processing of your personal information to authorized partners in order to authorize them to provide certain services or perform functions for you on our behalf. We will only entrust them with your information for the lawful, legitimate, necessary, specific, and defined purposes stated in this Policy. The authorized partner will only have access to the information needed to perform its duties. We will require by the agreement that it does not use the information for any other purpose beyond the scope of the entrustment. If an authorized partner uses your information for a purpose we have not delegated, it will obtain your consent separately. Currently, we have the following types of authorized partners: advertising and analytics partners (including cookies and similar technology third-party partners). We need to share some of your data with third party partners, such as advertisers and their agents for the purpose of advertising, evaluating and optimizing the effectiveness of advertising, etc. We will require them to strictly comply with our data protection measures and requirements, including but not limited to complying with the data protection agreement and Policy for processing data and avoiding identification of individuals to safeguard your privacy. We will not share information that can be used to identify you personally with such partners unless you expressly authorize us to do so.

In the event of applicable legal requirements or in response to legal proceedings, TRISTAR may also disclose your personal data to relevant law enforcement agencies or other government agencies. TRISTAR will also disclose your data in the presence of reasonable request. For example, execution of the contract and appropriate disclosure that we believe is necessary to prevent physical damage or property damage or to investigate possible or actual illegal conduct.

4. How to access or modify your personal data

You should ensure that all personal data submitted is accurate. TRISTAR will endeavor to maintain the accuracy and completeness of personal data and update these data in a timely manner.

When it is required by applicable law, you may have access to specific personal data we hold about you; ask us to update or correct your inaccurate personal data; deny or restrict us from using your personal data; ask us to delete your personal data. If you want to exercise the relevant rights, please provide feedback to us online. To ensure safety, you may need to provide a written request. We will refuse to process a request if we have a reasonable basis to believe that the request is deceptive, unenforceable, or harmful to the privacy of others.

You will also be entitled to cancel your consent at any time when TRISTAR processes your personal data based on your consent, as required by applicable law. However, the cancellation of the consent does not affect the legality and effectiveness of our processing of your personal data based on your consent prior to cancellation, nor does it affect our ability to process your personal data based on other appropriate justifications.

If you believe that our processing of your personal information does not comply with applicable data protection laws, you may contact a legal data protection agency. Please refer to the contact information of the EU data protection agency:

http://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm

5. How does TRISTAR protect and retain your personal data

TRISTAR values the security of personal data. We use appropriate physical, administrative, and technical measures to protect your personal data from unauthorized access, disclosure, use, modification, damage, or loss. For example, we use encryption technology to ensure data confidentiality; apply protection mechanisms to protect against malicious attacks; deploy access control mechanisms to ensure that only authorized personnel have access to personal data; and hold security and privacy protection training courses to enhance employees' awareness of the importance of protecting personal data. We will do our best to protect your personal data, but please note that any data transmitted over the Internet is not guaranteed to be 100% safe. Therefore, while we take appropriate steps to protect your personal information, TRISTAR cannot confirm or guarantee the security of the information you provide to us or from our Website, so access to our Website is at your own risk. For information on how to report security issues, matters, or possible events to the TRISTAR and TRISTAR information security team, please do not hesitate to contact us at [Privacy@TRISTAR.com]. In the event of a personal information security incident, we will promptly notify you and report to the regulatory authorities in accordance with the requirements of laws and regulations.

The personal data we collect will be stored and processed in your region, the European Union, the United States, and any other country where TRISTAR or its affiliates, subsidiaries, or service partners. TRISTAR's main data center is located in China and has strict data security protection and efficient operating mechanisms to avoid the risk of service interruption or data leakage. We take appropriate control to ensure that the data collected under this privacy statement complies with the requirements of this statement and the applicable laws of the location where the data is located. We will retain your personal data for a period of time required to achieve the purposes described in this Policy, unless it is required by law or permission to extend the retention period. Because the data storage period may vary based on different scenarios and products and services, the criteria we use to determine the retention period include: the time required to retain personal data for the purpose of completing the business, including the provision of products and services, maintenance of corresponding transaction and business records, control and improvement of the performance and quality of products and services, guarantee of the safety of systems, products, and services, response to possible user inquiries or complaints, problem identification, etc.; whether users agree to extend the retention period; whether there are special requirements for retaining data required by laws and contracts. We will retain your registration information as long as your account is required to provide services to you. You can also choose to cancel your account. After you cancel your account, we will stop providing products and services based on this account and delete your corresponding personal data without special legal requirements.

Our breach procedures ensure that we have safeguards and measures to identify, assess, investigate, and report any personal data breach as soon as possible. Our procedures are robust and have been disseminated to all employees, making them aware of the reporting lines and steps to follow.

6. How does TRISTAR process children's personal data

Our products, Websites, and services are primarily for adults. Children may not create their own user accounts without the consent of their parents or guardians. For the collection of children's personal data with parental consent, we will only use or disclose these data if it is permitted by law, obtains explicit consent of the parent or guardian, or is absolutely necessary to protect the children. If TRISTAR finds that it has collected the children's personal data without prior verifiable parental consent, we will try to delete the data as soon as possible.

7. Third party providers and their services

To ensure a smooth browsing experience, you may receive content or web links from TRISTAR and our partners (hereinafter referred to as "third parties"). TRISTAR has no control over such third parties. You can choose whether to access links, content, products, and services provided by third parties. TRISTAR cannot control the privacy and data protection policies of third parties, and such third parties are not bound by this Policy. Please refer to the privacy policies of these third parties before submitting personal information to them.

8. How your personal data is transferred globally

Since TRISTAR is a global company, we may share your personal information within TRISTAR (including subsidiaries, affiliates, and parent companies) or with our suppliers and business partners as permitted by law, and may transfer information to other countries where we have businesses. In such cases, TRISTAR will take steps to ensure that the data we collect is processed in accordance with the requirements of the Policy and applicable laws. When the personal data of the data subject located in the EU is transferred to a country or region where the European Union does not accept the same data protection level, TRISTAR will use various legal mechanisms, such as signing the standard contract terms approved by the European Commission or requesting your consent of cross-border transferring of personal data or implementing security measures such as data anonymity before transferring cross-border data.

Where TRISTAR stores or transfers personal information, we have robust procedures, and safeguarding measures in place to secure, encrypt, and maintain the integrity of the data. Our procedures include a continual review of the countries with sufficient adequacy decisions, as well as provisions for binding corporate rules; standard data protection clauses, or approved codes of conduct for those countries without. We carry out strict due diligence checks with all recipients of personal data to assess and verify that they have appropriate safeguards in place to protect the information, ensure enforceable data subject rights, and have effective legal remedies for data subjects where applicable.

9. How to update this Policy

TRISTAR reserves the right to update or modify this Policy on a regular basis. If our privacy Policy changes, we will post the latest version of our privacy Policy here. If we make material changes to our privacy Policy, we may also send you notifications of changes through different channels, such as posting a notice on our Website or sending an email (sent to the email address specified in your account) to inform you. Based on applicable data protection laws, we will also seek your consent for any material changes affecting how we use your personal information. We encourage you to check this page regularly for the latest information on our privacy practices.

10. How to contact the TRISTAR

The TRISTAR has designated DPO and has appointed a data privacy team to develop and implement our roadmap for complying with the new data protection Regulation. The team is responsible for promoting awareness of the GDPR across the organization, assessing our GDPR readiness, identifying any gap areas, and implementing new policies, procedures, and measures.

If you have any questions, comments, or suggestions, please contact us by emailing Privacy@TRISTAR.com.

When TRISTAR processes your personal data in accordance with this Privacy Policy, the TRISTAR Entity that responds to your request, contacts you, provides you with products or services, or concludes or signs a contract with you is the controller of the relevant personal data. For the contact information for each TRISTAR entity, please Click www.TRISTAR.com to view.

Last updated: November 2022