UNESCO x LKK: GLOBAL FOREVER FLAVORS Privacy Policy

Last Updated: February 2026

Lee Kum Kee International Holdings Limited (“Lee Kum Kee”, “we”, “us”, “our”) has established this UNESCO x LKK: GLOBAL FOREVER FLAVORS Privacy Policy (this “Policy”) to describe how your information is collected, used, stored, shared and protected , in accordance with applicable law, including but not limited to the Personal Information Protection Law, the UK and EU General Data Protection Regulation and the California Consumer Privacy Act, when you access and use the Site and/or participate in the Campaign.

It also describes your data protection rights, including the right to object to some of the processing Lee Kum Kee carries out. More information about your rights, and how to exercise them, is set out in the “Privacy Rights and Information Control” section. 
By accessing the Site and/or participating in the Campaign, you acknowledge that we process your personal information in accordance with this Policy. Please read all provisions of this Policy carefully before accessing or using the relevant services. 
 

Your access to the Site and participation in the Campaign also require your agreement to the UNESCO x LKK: GLOBAL FOREVER FLAVORS Terms and Conditions (the “Terms”). This Policy constitutes an integral part of the Terms. Unless otherwise defined in this Policy, all capitalized terms shall have the same meanings as those defined in the Terms.
If you are under the legal age of majority in your jurisdiction, your legal representative (such as a parent or guardian) must read and accept this Policy on your behalf. 
 

1. Information Lee Kum Kee Collects

1.1 Information You Provide

Lee Kum Kee may collect the information you choose to provide when accessing the Site and/or participating in the Campaign, including but not limited to: 
(a)    Contact and profile information: name (or display name), email address, age, city/region/country and other profile details you choose to submit, such as mobile phone number;
(b)    Submission content/ user generated content: written stories, photographs, videos, audio files, captions, descriptions, and/or other information or media you submit as part of your entry (“Submitted Content”);  
(c)    Communications: information you provide when you contact us (through email, social media channels or otherwise), such as inquiries, feedback, or messages regarding the Campaign; 
(d)    Preferences and voluntary information: Your preferences for flavor types, relevant experience descriptions, survey responses, or other information you voluntarily submit during Campaign participation or we request for identity verification and certificate delivery purposes (if your submission is approved or selected for recognition) such as your legal full name and contact details or details of your parent or guardian.
 

1.2 Information Collected Through Your Use of the Site

When you visit or interact with the Site, we may also automatically collect certain technical and usage information, including:
(a)    Identifiers: a unique submission ID / reference number (UID), certificate ID (if applicable), and other internal identifiers used to administer the Campaign; 
(b)    Log and usage data: Internet Protocol (IP) address, navigation behavior (e.g., pages viewed and interactions), date/time/duration of visits, and similar usage information;
(c)    Device and software information: device type, browser type, operating system, and other parameters related to your operating system and computer environment;
(d)    Anti-abuse/security signals: where we use anti-bot measures (e.g., CAPTCHA), we may receive risk-related technical signals to help prevent fraudulent or automated submissions.
 

We use cookies or similar technologies to collect some of the above information. Please see our Cookies Policy for more information.

1.3 Information Collected from Third Parties

We may also receive information about you from third parties. If you participate in activities on non-Lee Kum Kee sites or apps – such as submitting your Submitted Content via Red Note/Xiaohongshu – you may allow us to have access to personal information held by Red Note/Xiaohongshu, or other site or app owners.
In addition, you may be identified in the Submitted Content provided by another individual (e.g., in a photo or video).

1.4 Consequences of Not Providing Information

If you choose not to provide the required information for certain features of the Site or participation in the Campaign, or if you provide information that is inaccurate, incomplete, or misleading, this may result in the following consequences: 
(a)    Limited participation: you may be unable to submit a story, upload files or otherwise participate in the Campaign, and we may be unable to process your entry or allow you to participate in the Campaign; 
(b)    Inability to verify or administer entries: we may be unable to verify the authenticity of your submission, moderate or review your entry, or manage your participation in the Campaign; 
(c)    Restricted communication and recognition: we may be unable to contact you regarding your submission, notify you of selection results, or deliver any certificate or recognition (if applicable); 
(d)    Publication limitations: we may be unable to publish your story or display your submission as part of the Campaign, or we may need to remove it if required information is missing or cannot be validated; 
(e)    Limited support and response to requests: we may be unable to respond to your inquiries or to verify your identity for the purpose of handling privacy requests (e.g., request for access, deletion, or withdrawal of consent). 
 

Please note that where certain information is optional, you may still participate, but the relevant features or experiences may be limited accordingly. Where permitted by law, we may also reject or suspend a submission that cannot be verified or that appears to contain false or misleading information.
 

2. Use of Information

Lee Kum Kee may use your information for the following purposes for as long as such purposes remain necessary, and in any event as set out in the “Retention and Deletion of Information” section below. Unless otherwise permitted by law, we will obtain your consent before using your information for any purpose not described in this Policy. If you are a UK/EU resident please see the “EU and UK General Data Protection Regulation Addendum (“GDPR”)” section below for more detail on the legal basis relied on for the purposes specified below. 

2.1 Provide and Manage Site Services

We process your information as necessary to provide you with the services of the Site and to fulfil our obligations under the Terms. We may also use your information to provide, operate, maintain, and improve the Site, including to enable key functions (e.g., displaying content, handling submissions, troubleshooting, and monitoring performance), including via placement of cookies and similar technologies.
We may also use your information to protect the legitimate rights and interests of you and Lee Kum Kee, including preventing and investigating illegal activities, fraud, violations of the Terms and this Policy, and ensuring the security of the Site and the related service.

2.2 Provide and Manage Campaign Participation

We may use your information to administer your participation in the Campaign, including to receive and process the Submitted Content, associate your submission with a unique identifier, and manage participant records.

2.3 Content Review, Moderation and Publishing

We may review, moderate, and manage the Submitted Content (including stories and uploaded media) to: (i) enforce the Terms; (ii) ensure content suitability and brand safety; (iii) detect and prevent illegal, infringing, abusive, or otherwise prohibited content; and (iv) determine whether and how submissions will be published or displayed as part of the Campaign, including for any additional publicity activities.

For the Submitted Content you upload, Lee Kum Kee will take technical measures to protect its integrity and security. If your content involves sensitive personal information, Lee Kum Kee will apply measures to de-identify or redact such data before public display, unless you or the relevant individual has provided your explicit consent or we can rely on another lawful condition to process such content (such as data which you manifestly make public) to the display of original information.

2.4 Verification / Anti-abuse

We may use technical information (e.g., IP address, device/browser information, and anti-bot signals) including via placement of cookies and similar technologies to verify submissions, prevent fraud, spam, or automated submissions, and protect the security and integrity of the Site and Campaign.

2.5 Selection, Recognition and Certificate Issuance

We may use your information to review and select stories, manage shortlists, further verify your identity and to generate and assign a unique certificate number or reference number to selected submissions. We may also use such information to generate, issue, and maintain certificates or other forms of recognition related to the Campaign.

2.6 Participant Communications

We may use your contact information (such as your email address) to communicate with you regarding the Campaign, including to: (i) confirm receipt of your submission; (ii) obtain additional information from you regarding your submission; (iii) provide updates on your submission status (where applicable); (iv) notify you of selection/recognition outcomes; (v) send you information on how to access or download your certificate (if applicable).

2.7 Legal, Compliance and Risk Management

We may use your information to comply with applicable laws and regulations, respond to lawful requests by public authorities, exercise or defend legal claims, and maintain audit logs and records necessary for security and compliance purposes.

2.8 Handling Requests and Complaints

We may use your information to handle complaints, reports (e.g., copyright infringement or rights complaints), and to process and verify privacy rights requests (e.g., access, correction, deletion, withdrawal of consent).

2.9 Aggregated Reporting (Non-identifiable)

Where feasible, we may compile aggregated and/or de-identified statistics (e.g., number of submissions by region) for internal reporting, analytics, and campaign management, without identifying individuals.

3. Sharing of Information

Lee Kum Kee will strictly abide by the principle of data minimization and explicit consent (where required by applicable laws), when sharing your information, and will only share your information with third parties in the following circumstances:

3.1 Third-Party Service Providers

We may share your information with our trusted service providers who process information on our behalf and under our instructions, including providers assist with website development and hosting, content management, campaign operations, security and anti-abuse measures, email delivery, and technical support. Each service provider is contractually obligated to protect and keep your information confidential.

For this Campaign, key service providers may include:

(a)    Dentsu / TagWorldwide (website development, hosting, campaign operation and administration);
(b)    Cloud service providers and CDNs (hosting and content delivery (e.g., AWS, Akamai));
(c)    hCaptcha (anti-bot / anti-abuse for webforms); and
(d)    AddToAny (social sharing functionality, if users choose to use the sharing buttons).

3.2 Shared Use Among Affiliates

Lee Kum Kee may share and jointly use your information with its subsidiaries, fellow subsidiaries, affiliates and/or associate companies, whether existing now or established in the future, and whether directly or indirectly controlled by, controlling, or under common control with Lee Kum Kee (“Related Companies”) for the purpose of implementing the Campaign and providing consistent services. In such cases, Lee Kum Kee will ensure that the Related Companies comply with this Policy and assume responsibility for the protection of your information to the extent required by applicable law.

3.3 Sharing with Campaign Partners

Lee Kum Kee may share your necessary information with Campaign partners (including but not limited to UNESCO) for the purposes of Campaign operation, promotion, public welfare publicity and outstanding work selection. The information shared will be strictly limited to what is necessary for achieving the above purposes, and Lee Kum Kee will enter into data protection agreement with UNESCO and other partners to clarify the rights and obligations and to ensure your information is handled securely and in compliance with this Policy and relevant international standards.

3.4 With Your Explicit Consent

Where required by applicable laws, Lee Kum Kee will only share your information with other third parties with your explicit written consent or express authorization.

3.5 Compliance with Legal Obligations

Lee Kum Kee may disclose your information to third parties without your consent if such disclosure is required or permitted by applicable laws, regulations, judicial decisions or administrative orders, or if it is necessary to protect the legitimate rights and interests of Lee Kum Kee, you or third parties or to respond to public health emergencies.

3.6 Prospective purchasers and their advisers

Lee Kum Kee may share your necessary information with our advisers and any prospective purchaser’s adviser in the event that the business is sold or integrated with another business, and will be passed on to the new owners of the business.

4. Privacy Rights and Information Control

4.1 Your Privacy Rights

In accordance with applicable laws, regulations and guidelines, you have the following rights regarding your personal information:
(a)    Request confirmation of whether Lee Kum Kee is processing your personal information;
(b)    Request access to or obtain a copy of your personal information;
(c)    Request to receive an electronic copy of the personal information you provided, or request Lee Kum Kee to transmit such information to a third party designated by you (right to data portability);
(d)    Object to or restrict Lee Kum Kee's processing of your personal information;
(e)    Request correction or supplementation of inaccurate, incomplete or outdated personal information;
(f)    Withdraw your consent to the processing of personal information (the withdrawal of consent will not affect the validity of any processing carried out before the withdrawal);
(g)    Request Lee Kum Kee to delete your personal information, subject to the exceptions prescribed by applicable laws and regulations.

These rights may be limited, for example if fulfilling your request would reveal personal information about another person, or if you ask us to delete information which we are required by law or have compelling legitimate interests to keep. 

If you wish to exercise any of these rights, please contact us at the contact details set out below. 

Wherever we rely on your consent, you have the right to withdraw that consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal. We may, however, have other legal grounds for processing your data for other purposes, such as those set out above.

For California residents, the rights described in this Section are supplemented by the additional rights set forth in Section 8.1 (California Privacy Rights Addendum).

If you are a UK resident, the rights described in this Section are also supplemented by the additional rights set out in Section 8.2 (EU and UK General Data Protection Regulation Addendum (“GDPR”))

We will not discriminate against you for exercising any of your rights under the applicable laws.

4.2 Protection of Minors and Parental Rights

A parent or legal guardian may withdraw their consent for the processing of a minor participant’s personal information (where consent is the lawful basis relied on for such processing under applicable data protection laws and where the minor is unable to give or withdraw the consent themselves) at any time by contacting us at foreverflavorsproject@lkk.com (please include “UNESCO x LKK: GLOBAL FOREVER FLAVORS – Minor Consent Withdrawal” in the email subject line). Upon receipt of such withdrawal, Lee Kum Kee will cease the use of the minor’s personal information as promptly as practicable, subject to the limitations set forth in the last paragraph under Section 5. The parent or legal guardian acknowledges that complete removal of materials already published or disseminated may not be possible, as described in Section 5. 

For California residents under the age of 16, Lee Kum Kee will not sell or share personal information without affirmative authorization, and parental consent will be obtained where required by law.
For California residents under the age of 13, Lee Kum Kee will comply with the Children’s Online Privacy Protection Act (COPPA), including obtaining verifiable parental consent prior to collecting, using, or disclosing any personal information, and implementing additional safeguards to protect your privacy. Lee Kum Kee will provide direct notice to parents regarding the types of personal information collected, the purposes for which it is used, and with whom it may be shared.
 

For users located within Mainland China, if you are a minor under the age of fourteen, we will obtain the explicit consent of your parent or other guardian prior to collecting or using your personal information. We will only process such information where permitted by laws and regulations, with the explicit consent of your guardian, or where necessary to protect minors.
 

For users located within the UK, if you are a minor under the age of 13, we will obtain the explicit consent of your parent or other guardian prior to collecting or using your personal information (where we rely on consent under UK GDPR as the lawful basis to process your personal information).
 

For users located within the EU, if you are a minor, in accordance with local Member State data protection laws, we will obtain the explicit consent of your parent or other guardian prior to collecting or using your personal information (where we rely on consent under the EU GDPR as the lawful basis to process your personal information).
 

To the extent permitted by applicable law, parents or legal guardians have the right to: (a) review the personal information collected from their child; (b) request the deletion of their child’s personal information; (c) refuse to permit further collection or use of their child’s information; and (d) revoke their consent at any time. To exercise these rights, parents or legal guardians may contact Lee Kum Kee at foreverflavorsproject@lkk.com. Lee Kum Kee will respond to such requests within a reasonable timeframe, not exceeding one calendar month from receipt of the request. Please also see section 4.3 below.
 

4.3 How to Exercise Your Rights

If you wish to exercise any of the above rights, or if you are the parent or guardian of a minor (who is unable to exercise these rights on their own under applicable laws) and wish to exercise rights on behalf of the minor, please send an email to foreverflavorsproject@lkk.com (please indicate “UNESCO x LKK: GLOBAL FOREVER FLAVORS - Privacy Rights Request” in the email subject line) and provide sufficient information to verify your identity (such as the name and email address when making submission) and any authorisations to make such requests on another’s behalf. Lee Kum Kee will action your request in accordance with applicable laws and regulations within a reasonable time limit after receiving your valid request, not exceeding one calendar month from receipt of your request.

UK and EU residents: If you have unresolved concerns, you also have the right make a complaint to the data protection authority in the country that you reside in or, the country of your place of work or the country where the alleged infringement took place. A list of authorities in the EEA can be found here. In the UK, this will be the Information Commissioner.
 

Please note that the withdrawal of consent or the request for deletion of personal information may affect your ability to continue accessing the Site, using relevant services or participating in the Campaign. If you have any questions about the exercise of your rights, you may contact Lee Kum Kee through the contact information set out above.
 

4.4 Circumstances Where Information May Not Be Disclosed

Notwithstanding any other provisions of this Policy, Lee Kum Kee may refuse to disclose certain information to you in the following circumstances:

(a)    Disclosure may violate the legitimate rights and interests of yourself or third parties (such as causing physical harm, financial loss or infringement of privacy);
(b)    Disclosure is necessary to safeguard Lee Kum Kee's legitimate rights and interests (such as investigating fraud or violations);
(c)    Disclosure violates applicable laws, regulations, rules or the requirements of government departments, judicial authorities or law enforcement agencies.

If Lee Kum Kee decides not to disclose certain information, you will be notified of such decision and the reasons therefore without delay, to the extent permissible by laws.

5. Information Protection Measures

Lee Kum Kee is committed to the security of your information and has formulated and implemented a comprehensive information security management system in accordance with international and industry standards, including but not limited to the following measures:

(a)    Technical protection: Adopt industry-standard encryption technologies (such as SSL/TLS encryption) to protect the security of information during transmission and storage, implement access control mechanisms to strictly limit the scope of personnel accessing your information and conduct regular security audits;
(b)    Institutional protection: Establish a personal information protection management system, appoint a special personal information protection officer to supervise the entire process of information processing, conduct regular compliance training for employees to enhance their awareness of information protection;
(c)    Organizational security: We have a dedicated information security team that is responsible for delivering regular training to enhance employees' information security awareness, as well as conducting oversight of full-cycle security compliance throughout the information processing workflow;
(d)    Emergency response: Formulate a data security incident response plan. In the event of an information security incident (such as data leakage), timely initiate an emergency response, take measures to control the risk and minimize losses, and notify the relevant authorities and affected users in accordance with legal requirements;
(e)    Anonymization and pseudonymization: For data that does not require the identification of specific individuals (such as statistical data of campaign participation), conduct anonymization or pseudonymization processing to ensure that it cannot be associated with specific individuals.
 

To the extent permitted by applicable laws, Lee Kum Kee will not be liable for the leakage, loss or damage of information caused by factors beyond its reasonable control (such as failures of the communication network used by you, malicious attacks by third parties).

6. Cross-Border Transfer of Information

To achieve the purposes specified in Section 2 of this Policy, your information may be transferred, stored and processed in one or more countries and/or regions (including the locations of Lee Kum Kee's Related Companies and third-party service providers) which may be different to the country/region in which you reside. If this is the case, Lee Kum Kee will conduct a privacy impact assessment on such cross-border data transfers, and take appropriate measures/ adopt mechanisms in accordance with applicable laws of the jurisdiction where the personal information are transferred to, stored in or processed, to ensure that the security of your information is effectively protected, using mechanisms such as but not limited to the EU Standard Contractual Clauses or UK International Data Transfer Addendum if required. 

For detailed information about specific overseas recipients, including their names, contact information, purposes and methods of processing, and types of information involved, and the data transfer mechanisms we use, you may contact us at foreverflavorsproject@lkk.com.

7. Retention and Deletion of Information

7.1 Retention Period for Unselected Submissions

If your Submitted Content is not selected for the Campaign, Lee Kum Kee will delete your personal information and relevant submission content within six (6) months from the determination that your submission is not selected, unless otherwise required by applicable laws and regulations or necessary for fulfilling legal obligations.

7.2 Retention Period for Selected Submissions

If your Submitted Content is selected and published as part of the Campaign, Lee Kum Kee will retain your relevant information for the period necessary for the publication and related publicity purposes. We will subsequently take necessary steps to securely destroy your personal information when it is no longer necessary for the purposes they were collected, or as otherwise required by law, whichever is earlier. You may also request the deletion of your information at any time in accordance with Section 4 of this Policy. However, you acknowledge that once the content is published and enters the public domain, it may not be possible to completely remove all copies or references from the Internet or other public channels. Lee Kum Kee will use reasonable efforts to delete your information from its own platforms and request relevant third-party platforms to delete it (if feasible), but, to the extent permitted by applicable laws, will not be liable for the failure to completely delete such information due to factors beyond its control.

7.3 Retention period for other personal information

We otherwise process any other information as necessary for us to continue to provide you with the information and services necessary in connection with your use of the Site and the Campaign. These vary based on the type of personal information, service and country/region. We take necessary steps to destroy your personal information when it is no longer necessary for the purposes they were collected, or as otherwise required by law, whichever is earlier.

8. Jurisdiction-Specific Terms

8.1 California Privacy Rights Addendum

This Section applies only to residents of the State of California and is provided pursuant to the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act (“CCPA/CPRA”). In the event of any conflict between this Section and other provisions of this Policy, this Section shall control with respect to California residents.

(a)    Categories of Personal Information Collected
Within the preceding twelve (12) months, Lee Kum Kee may have collected the following categories of personal information from California residents in connection with the Site and/or Campaign:
(i)    Identifiers, such as name, display name, email address, unique submission ID, and certificate ID;
(ii)    User-Generated Content, including stories, photographs, drawings, videos, audio files, captions, and other creative submissions;
(iii)    Internet or Electronic Network Activity Information, including IP address, browser type, device information, and interaction data;
(iv)    Geolocation Information, limited to general location such as city, region, or country;
(v)    Sensitive Personal Information, limited to personal information of minors, where applicable.
 

Lee Kum Kee does not knowingly collect precise geolocation data or government-issued identification numbers.
 

(b)    Purposes for Collection and Use
Personal information is collected and used for the purposes described in Section 2 of this Policy, including but not limited to Campaign administration, content review and publication, participant communications, security, and legal compliance. Lee Kum Kee does not use personal information collected through the Campaign for targeted advertising, cross-context behavioral advertising, or profiling within the meaning of the CPRA.

(c)    Sale or Sharing of Personal Information
Lee Kum Kee does not sell personal information for monetary consideration.
Lee Kum Kee does not share personal information for cross-context behavioral advertising. To the extent that sharing with Campaign partners (including UNESCO) may constitute “sharing” under the CPRA for non-advertising purposes, such sharing is limited strictly to Campaign operation, public-interest objectives, and recognition activities as described in this Policy.
California residents have the right to opt out of any such sharing by contacting: foreverflavorsproject@lkk.com.

(d)    Retention of Personal Information
Personal information is retained only for as long as reasonably necessary to fulfill the purposes described in this Policy, as further detailed in Section 7. Retention criteria include campaign duration, publication and archival purposes, legal and compliance obligations.

(e)    California Consumer Rights
California residents have the right to:
(i)    Request disclosure of the categories and specific pieces of personal information collected;
(ii)    Request deletion of personal information, subject to statutory exceptions;
(iii)    Request correction of inaccurate personal information;
(iv)    Limit the use and disclosure of sensitive personal information;
(v)    Opt out of the sale or sharing of personal information;
(vi)    Not be discriminated against for exercising privacy rights;
(vii)    Parents or legal guardians may exercise these rights on behalf of their minor children;
 

Requests may be submitted as described in Section 4.3 of this Policy.

8.2 EU and UK General Data Protection Regulation (“GDPR”) Addendum 

This Section applies to residents of the EU or United Kingdom pursuant to, as applicable to the processing, the GDPR (Regulation 2016/679) or UK GDPR as defined in s.3(10) of the UK Data Protection Act 2018. In the event of any conflict between this Section and other provisions of this Policy, this Section takes shall take precedence.
 

Where your personal information is processed for the purposes noted in Section 2. Use of Information above, Lee Kum Kee may use your information for the following legal bases:

In the UK, where processing of personal information for any of the listed purposes above is necessary to process personal information to prevent, detect, or investigate a crime, we rely on our recognised legitimate interests.
 

In addition to the ICO, you also have a right to make a complaint to us using the contact details above if you have any unresolved concerns about how we process your personal information.
 

9. Changes to This Policy

Lee Kum Kee reserves the right to update or modify this Policy in response to changes in applicable laws and regulations, adjustments to Campaign content or changes in business needs. If there are material changes to this Policy (such as changes in the scope and purpose of information collection and use), Lee Kum Kee will prominently notify you through the Site's homepage, pop-up windows or other reasonable methods before the changes take effect, and obtain your explicit consent to these changes if required by law.

The updated Policy will take effect on the date of publication. Your continued access to the Site or participation in the Campaign after the Policy is updated constitutes your acceptance of the updated Policy. It is recommended that you regularly review the latest version of this Policy on the Site.

10. Contact Information

If you have any questions, suggestions or complaints about this Policy or the processing of your information, please contact Lee Kum Kee by email at foreverflavorsproject@lkk.com (please indicate “UNESCO x LKK: GLOBAL FOREVER FLAVORS - Privacy Policy Inquiry” in the email subject line).

For EU and UK residents, Lee Kum Kee is the relevant data controller.

If you are based in the European Union, we do not have an establishment in the European Union; therefore, we have appointed a local representative, EU-REP.Global GmbH, based at Hopfenstr. 1d, 24114 Kiel, Germany, who you can contact. Our EU representative can be contacted directly by emailing them at lkk@eu-rep.global, with the reference Attn: Lee Kum Kee.
 

Save for where it relates to actioning any privacy rights you exercise in accordance with Section 4 above, Lee Kum Kee will reply to you within ten (10) working days after receiving your inquiry and handle it in a timely manner in accordance with applicable laws and regulations.