1. WHO IS ACCOUNTABLE FOR PROCESSING MY PERSONAL DATA?
Building A3, Daning Central Plaza, 700 Wanrong Road, Shanghai
is responsible for processing your personal data on this website (hereinafter referred to as “we”).
We process personally identifiable information (“personal data”) in accordance with the relevant laws, regulations and standards of China as well as the general practices of other countries and regions.
You can contact our designated Data Protection Center at the address indicated above.
2. WHAT DATA IS COLLECTED?
When you visit our website, the data of the computer you use to access our website is automatically logged (“access data”). This access data includes server log files that generally consist of information pertaining to your web browser type and version, your operating system, your internet service provider (ISP), the date and time you used the website, the websites previously visited by you and the websites you accessed from our website, in addition to the IP address of your computer. With the exception of your IP address, the information contained in the server log files is not personally identifiable. An IP address is personally identifiable when it is static (permanently allocated when using internet access) and the ISP is able to attribute it to a specific person.
3. WHAT COOKIES ARE USED?
As a general principle, cookies enable online recognition without reference to a specific person. Cookies may become personally identifiable when the information they contain is merged with other information apart from the information generated by the cookies themselves.
The cookies that are required for the provision of website features include the following in particular:
4. WHAT PERSONAL DATA IS COLLECTED AND FOR WHAT PURPOSE?
The purpose of data processing may be based on technical, contractual or statutory requirements or result from consent having been given by the user.
We use the data described in section 2 for the following purposes:
4.1 PROVISION OF THE WEBSITE
4.1.1 DESCRIPTION AND SCOPE OF DATA PROCESSING
In order to enable the proper functioning of our website, security analyses to be conducted, and denial-of-service attacks to be prevented and stopped, server log files are automatically collected and saved on a short-term basis as an integral part of access data that is created by the system of the visiting computer upon accessing our website and while using it (see section 2). The content of the server log files is not merged with other data. We use the server log files for statistical analyses to troubleshoot and remedy technical issues, prevent and defend against denial-of-service attacks and attempted fraud, and to optimize the proper functioning of our website.
4.1.2 PURPOSE AND LEGAL BASIS OF DATA PROCESSING
The legal basis for the creation of server log files follows from the relevant laws, regulations and standards of China as well as the general practices of other countries and regions. Our legitimate interests lie in the proper functioning of our website, conducting security analyses and defending against threats.
4.1.3 DURATION OF STORAGE OR CRITERIA APPLIED IN DEFINING THIS PERIOD
When the pages of our website are accessed, information is logged to server log files that are stored on our web server; the IP address contained in them is deleted after 7 days at the latest. No analysis is conducted during this time unless there is a denial of service or other attack.
4.1.4 OPTIONS FOR LODGING AN OBJECTION AND HAVING YOUR DATA REMOVED
You have the right to lodge an objection to the processing of your data contained in the server log files provided that there are cogent reasons that arise from your specific situation. If you would like to exercise your right to lodge an objection, please write to the contact address in section 1.
4.2 CONTACT FORM, EMAIL, CHATBOT AND TELEPHONE CONTACT INFORMATION
4.2.1 DESCRIPTION AND SCOPE OF DATA PROCESSING
On our website you have the option of contacting us by way of a contact form, by email, by telephone using the designated email address and phone number. If you take advantage of this option, the information you enter in the contact form, your email address and/or your phone number are disclosed to us. Depending on the reason you are contacting us (questions about our products and services, pursuing your rights as a data subject, e.g. submitting a request for information) your contact details are processed (with the assistance of service providers). If necessary for processing your request, this information may be shared with third parties (e.g. partner companies).
4.2.2 PURPOSE AND LEGAL BASIS OF DATA PROCESSING
The legal basis for processing your contact details follows from the relevant laws, regulations and standards of China as well as the general practices of other countries and regions. We have legitimate interests in processing your request and in continued communication.
4.2.3 DURATION OF STORAGE OR CRITERIA APPLIED IN DEFINING THIS PERIOD
Your contact details are deleted once your request has been processed and further communication has been discontinued. This does apply if the purpose of your establishing contact with us is to conclude a contract or you wish to exercise your right as a data subject (e.g. request information). In this case your details are stored until all contractual and/or statutory obligations have been fulfilled.
4.2.4 OPTIONS FOR LODGING AN OBJECTION AND HAVING YOUR DATA REMOVED
You have the right to lodge an objection to the processing of your contact information provided that there are cogent reasons that arise from your specific situation. If you would like to exercise your right to lodge an objection, please write to the contact address in section 1. If you lodge an objection, communication with you cannot be continued. This does not apply if the storage of your contact details is necessary for completing precontractual procedures, fulfilling a contract or exercising your rights as a data subject.
4.3 ASSERTING YOUR RIGHTS AS A DATA SUBJECT
4.3.1 DESCRIPTION AND SCOPE OF DATA PROCESSING
On the website you have the possibility of asserting your rights as a data subject, e.g. request information on your personal information that is currently stored by us. In order to assert your rights as a data subject, it may be necessary that you provide us information pertaining to your person and the specific information that has been processed. Without providing this information, we are not able to cater to your rights as a data subject.
4.3.2 PURPOSE AND LEGAL BASIS OF DATA PROCESSING
The legal basis for processing your personal information in asserting your rights as a data subject follows the relevant laws, regulations and standards of China as well as the general practices of other countries and regions.
4.3.3 DURATION OF STORAGE OR CRITERIA APPLIED IN DEFINING THIS PERIOD
We store the correspondence exchanged with you in relation to your asserting your rights as a data subject for a period of three years. This does not apply to information stipulated in 4.2 CONTACT FORM, EMAIL, CHATBOT AND TELEPHONE CONTACT INFORMATION.
4.3.4 OPTIONS FOR LODGING AN OBJECTION AND HAVING YOUR INFORMATION REMOVED
The processing of your information is required for complying with your rights as a data subject, and to that extent you have no right to revoke your consent to its processing.
5. WHO COMES INTO POSSESSION OF MY PERSONAL DATA?
Within our company those who need access to your information for the purposes described in section 4 will be given access to it. Service providers contracted by us may also be given access to your information (“contract data processors”, e.g. data centers, mailing services for newsletters, web tracking). They are bound by our directives and must provide for data security and the confidential treatment of your information under the contract data processing agreements we have concluded with them.
No sharing of information with other recipients such as advertising partners, providers of social media services or credit institutions (“third parties”) takes place.
6. WHAT DATA PRIVACY RIGHTS DO I HAVE?
You have the right to request access to your personal data that is currently stored by us. If this data is incorrect or not up to date, you have the right to request rectification. You also have the right to have your personal data erased and/or its processing restricted as provided for in relevant laws, regulations and standards of China, as well as the general practices of other countries and regions. You also have the right to request a copy of the personal data provided by you in a structured, commonly-used, machine-readable format (right to data portability).
If you have given your consent to the processing of your personal information for specific purposes, you can revoke that consent at any time for the future. Your notice of revocation is to be addressed to us by writing to the contact address indicated in section 1.
You also have the right to lodge an objection to the processing of your personal information for direct marketing purposes. The same applies to automated processes involving the use of individual cookies, unless they are required for providing the functionality of our website.
7. TO WHAT EXTENT DOES AUTOMATED DECISION-MAKING TAKE PLACE?
We do not use any fully automated decision-making processes for any of the purposes set out in section 4.