SEESALT Initiative DAta and PRIVACY POLICY

Effective Date: January 1, 2025
Last Updated: January 1, 2025

by SEESALT Initiative Core Management Committee

1. INTRODUCTION

SEESALT Institute ("SEESALT," "we," "us," or "our") respects your privacy and is committed to protecting your personal data. This Privacy Policy governs the collection, use, disclosure, retention, and protection of personal information submitted by or collected from applicants, participants, alumni, partners, and other individuals who interact with our initiative. This Policy applies to all SEESALT programs, platforms, websites, and services worldwide. By engaging with SEESALT or submitting an application to our programs, you acknowledge that you have read, understood, and agree to be bound by this Privacy Policy.

2. DATA CONTROLLER INFORMATION

SEESALT Institute operates as the data controller for personal information processed under this Policy. We determine the purposes and means of processing personal data in accordance with applicable data protection laws, including but not limited to the General Data Protection Regulation (GDPR), California Consumer Privacy Act (CCPA), Personal Information Protection Law of the People's Republic of China (PIPL), and other relevant national and international data protection frameworks. For questions regarding data processing or to exercise your rights under this Policy, please get in touch with our Data Protection Officer at cat661@aliyun.com.

3. LAWFUL BASIS AND PURPOSES OF PROCESSING

We process personal data based on the following lawful grounds: (a) consent, obtained through clear affirmative action; (b) contractual necessity, for the performance of program agreements and service delivery; (c) legal obligations, to comply with applicable laws and regulations; (d) legitimate interests, pursued by SEESALT or third parties, except where such interests are overridden by your fundamental rights and freedoms; and (e) vital interests, in emergency situations affecting life or physical safety. Personal data is collected and processed exclusively for specified, explicit, and legitimate purposes, including but not limited to: application evaluation and selection processes; program administration and delivery; participant safety and welfare; academic and professional development support; impact assessment and research; alumni network management; fundraising and development activities; and compliance with legal and regulatory requirements.

4. CATEGORIES OF PERSONAL DATA

We collect and process the following categories of personal data: (a) identification information, including full legal name, date of birth, nationality, gender, and government-issued identification numbers where legally required; (b) contact information, comprising physical addresses, email addresses, telephone numbers, and emergency contact details; (c) educational and professional information, including academic transcripts, degrees, certifications, employment history, and professional references; (d) application materials, encompassing essays, statements of purpose, creative portfolios, and letters of recommendation; (e) program participation data, including attendance records, project submissions, performance evaluations, and peer feedback; (f) financial information, limited to that necessary for scholarship administration and program fee processing; (g) technical data, including IP addresses, device identifiers, browser information, and usage analytics; and (h) special category data, collected only with explicit consent, which may include ethnic origin, religious or philosophical beliefs, solely when relevant to program objectives or participant welfare.

5. DATA SHARING AND INTERNATIONAL TRANSFERS

SEESALT may share personal data with the following categories of recipients: (a) internal stakeholders, including staff members, advisory board members, and program mentors, on a need-to-know basis; (b) partner organizations, including host institutions, funding bodies, and collaborative program partners, subject to appropriate data protection agreements; (c) service providers, including cloud storage providers, communication platforms, payment processors, and analytics services, bound by contractual obligations to protect personal data; and (d) legal authorities, when required by law or valid legal process. As an international initiative, we transfer personal data across borders in furtherance of our global mission. Such transfers are conducted in compliance with applicable data protection laws and are subject to appropriate safeguards, including standard contractual clauses, adequacy decisions, binding corporate rules, or explicit consent. We maintain a record of all international data transfers and the safeguards applied thereto.

6. DATA RETENTION

Personal data is retained only for as long as necessary to fulfill the purposes for which it was collected, plus any additional period required by law or legitimate business needs. Our standard retention periods are as follows: application data for unsuccessful candidates is retained for one year following the selection decision; successful applicant data is retained for the duration of program participation plus five years thereafter for alumni relations and impact assessment; financial records are retained for seven years in accordance with applicable financial regulations; and anonymized or aggregated data used for research and statistical purposes may be retained indefinitely. Upon expiration of the applicable retention period, personal data is securely deleted or anonymized in accordance with our data disposal procedures.

7. DATA SUBJECT RIGHTS

In accordance with applicable data protection laws, you have the following rights regarding your personal data: (a) the right to access your personal data and obtain information about how it is processed; (b) the right to rectification of inaccurate or incomplete personal data; (c) the right to erasure ("right to be forgotten") under certain circumstances; (d) the right to restrict processing of your personal data in certain situations; (e) the right to data portability, to receive your personal data in a structured, commonly used, and machine-readable format; (f) the right to object to processing based on legitimate interests or for direct marketing purposes; (g) the right to withdraw consent at any time, where processing is based on consent; and (h) the right to lodge a complaint with a supervisory authority. Requests to exercise these rights should be submitted to cat661@aliyun.com and will be responded to within thirty days, or as otherwise required by applicable law.

8. DATA SECURITY

SEESALT implements appropriate technical and organizational measures to ensure a level of security appropriate to the risk, including: (a) pseudonymization and encryption of personal data; (b) measures to ensure ongoing confidentiality, integrity, availability, and resilience of processing systems; (c) ability to restore availability and access to personal data in a timely manner in the event of an incident; (d) regular testing, assessment, and evaluation of security measures; (e) staff training and awareness programs on data protection; and (f) access controls based on the principle of least privilege. Despite these measures, no method of transmission over the internet or electronic storage is completely secure. While we strive to protect your personal data, we cannot guarantee its absolute security.

9. CHILDREN'S PRIVACY

SEESALT does not knowingly collect personal data from children under the age of thirteen without verifiable parental consent. For participants between the ages of thirteen and eighteen, or the age of majority in their jurisdiction, we require parental or guardian consent for program participation and data processing. Parents and guardians have the right to review, correct, or request deletion of their child's personal data, and to withdraw consent for future processing. If we become aware that we have collected personal data from a child without appropriate consent, we will take steps to delete such information promptly.

10. COOKIES AND TRACKING TECHNOLOGIES

Our websites and platforms use cookies and similar tracking technologies to enhance user experience, analyze usage patterns, and improve our services. Essential cookies are necessary for the operation of our websites and cannot be disabled. Analytics and performance cookies help us understand how visitors interact with our platforms. You may control cookie preferences through your browser settings or by using our cookie consent tool. Disabling certain cookies may impact the functionality of our services. Our Cookie Policy, available on our website, provides detailed information about the types of cookies we use and how to manage them.

11. THIRD-PARTY LINKS AND SERVICES

Our platforms may contain links to third-party websites, services, or applications that are not operated by SEESALT. This Privacy Policy does not apply to such third-party services, and we are not responsible for their privacy practices. We encourage you to review the privacy policies of any third-party services you access through our platforms. When we integrate third-party services for program delivery or communication purposes, we ensure appropriate data protection agreements are in place to safeguard your personal data.

12. POLICY UPDATES

SEESALT reserves the right to update this Privacy Policy to reflect changes in our data processing practices, legal requirements, or business operations. Material changes will be communicated through prominent notice on our website and, where appropriate, via email notification to affected individuals. The updated Policy will indicate the effective date of the revisions. Continued use of our services following notification of changes constitutes acceptance of the updated Privacy Policy. We maintain an archive of previous versions of this Policy, which may be requested by contacting our Data Protection Officer.

13. GOVERNING LAW AND DISPUTE RESOLUTION

This Privacy Policy shall be governed by and construed in accordance with the laws of the People’s Republic of China, without regard to its conflict of law provisions. Any disputes arising from or relating to this Policy or our data processing practices shall first be subject to good faith negotiations. If resolution cannot be achieved through negotiation, Nothing in this Policy shall limit your right to file a complaint with the relevant data protection authority in your jurisdiction.

14. CONTACT INFORMATION

For questions, concerns, or requests regarding this Privacy Policy or our data processing practices, please contact:

Data Protection Officer
SEESALT Institute
Email: cat661@aliyun.com

You may also contact the supervisory authority in your jurisdiction for matters relating to data protection. We maintain a commitment to addressing all privacy-related inquiries in a timely and transparent manner, typically within thirty days of receipt.

By engaging with SEESALT services or submitting an application, you acknowledge that you have read, understood, and agree to this Privacy Policy in its entirety.