For the purpose of this China Notice, “Personal Information” means any electronic or otherwise recorded information related to identified or identifiable natural persons, excluding anonymized data.
The types of personal data we process may include:
We have collected the types of personal information outlined above about consumers in the last 12 months for business or commercial purposes. We may use or disclose personal information for one or more of the following business or commercial purposes:
We may need to provide information to third parties for a variety of reasons. Please refer to the section titled ‘How we will use your personal information’ which explains how we use your data. The third parties we share your information with are as follows:
Occasionally we may be required or authorised to collect personal information because of laws in China or an order of a Court / Tribunal. If we are collecting personal information for this purpose, and we are permitted to do so, we will tell you.
You are provided with a number of different rights under the PIPL in relation to your personal information. These allow you:
To exercise any of the above rights you do not need to use a particular form but you should write to us on the details given in the ‘Contact us’ section.
Your rights above may be subject to certain limitations, and we may not be required to fulfill all requests in all circumstances. For example, we may not be able to delete or anonymize all data as we may be legally required to retain certain data or retain certain data in identifiable form under applicable laws.
If you don’t provide us with the required personal information, we and our clients may not be able to provide you with some or all services. Where we collect personal information from you, we expect you to tell us if you do not consent to us disclosing the personal information you provide to us to the types of third parties referred to above. You have the right to withdraw consent at any time.
We process some of your data automatically to assess certain personal aspects (profiling), which is necessary to assist us to personalize and improve the quality of our services provided to you and to help us meet legal and regulatory requirements.
These tools allow our communications and marketing to be tailored to you as needed. You have the right to refuse the application of these tools, which may, however, affect our ability to manage a business relationship with or to provide well-tailored products and services to you. Please also note that this right is not available to you in certain situations (e.g. the automated-processing authorized by laws or regulations).
We will not discriminate against you for exercising any of your PIPL rights.
We protect personal data in our possession or under our control by making reasonable physical, technical, administrative and procedural security arrangements to prevent unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks.
We will only transfer your personal information outside China where you have given your consent to such transfer, and you are aware and understand the reason why the transfer is required. If your consent has been obtained, we may transfer personal data outside China.
We will use lawful cross-border transfer mechanism to transfer your Personal Information overseas and adopt necessary measures to ensure the overseas recipients can provide the same level of protection as required under applicable Chinese laws.
We will retain personal information for varying lengths of time based on the purposes for which it was obtained and the requirements of any applicable law or regulation. When determining how long to keep your personal information, we will consider the amount, nature, sensitivity, and intended use of the information, as well as the potential risk of damage from unauthorised use or disclosure. We regularly examine our retention periods for personal information and will guarantee that all records are securely destroyed if we no longer require them or if you contact us to do so.
We reserve the right to amend this Notice at our discretion and at any time. When we make changes to this Notice, we will notify you through a notice on our website homepage. Your continued use of our website following the posting of changes constitutes your acceptance of such changes.
If you have any questions regarding our privacy policies, the ways in which we collect, use, or disclose your personal information, or how to exercise your rights under the PIPL, please do not hesitate to contact us using the details given in the ‘Contact us’ section.
This policy has been last updated on 22nd Oct’22 and shall be applicable from such date on all our existing and prospective users.
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