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Privacy Policy

Privacy Policy

Preface

[As the only central enterprise focusing on human resources services, China International Intellectech Co., Ltd. (“CIIC”) is committed to providing a full range of HR services to clients at home and abroad. China International Intellectech (Shanghai) Co., Ltd. (“CIIC Shanghai”) is a wholly-owned subsidiary of CIIC and an important strategic member of CIIC’s national service network and strategic layout. The company’s main businesses consist of six sectors: HR outsourcing, HR management consulting, recruitment/headhunting/flexible employment and BPO, training, international HR services (including foreign labor cooperation and business services), and technical service and trade.] We are committed to maintaining your trust in us and protecting your personal information by observing the principles of consent and choice, purpose specification, limitation on data collected, data minimization, openness and transparency, accountability, guarantee of security, and privacy compliance. We value your privacy protection and personal information security and will take appropriate security measures following legal and regulatory requirements and established industrial security standards. This policy describes the policies for processing personal information collected in relation to the products or services of [CIIC Shanghai and its affiliates]. It shall be noted that CIIC Shanghai’s affiliates include but not limited to: CIIC Shanghai’s wholly-owned subsidiaries, holding subsidiaries, shareholding subsidiaries, and private non-enterprise institutions wholly-owned by CIIC Shanghai. In particular, this policy does not apply to your personal information collected by other third parties.

Please read and understand this Privacy Policy before using our products (or services). By using the products or services of CIIC Shanghai and its affiliates, you are deemed to have understood and fully agreed to this policy. If you have any questions, comments, or suggestions about the content of this policy, you may contact us by email ([privacy@ciicsh.com]).

This policy contains the following sections:

I. HOW WE COLLECT YOUR PERSONAL INFORMATION

II. HOW WE SHARE, TRANSFER, AND PUBLICLY DISCLOSE YOUR PERSONAL INFORMATION

III. HOW WE PROTECT YOUR PERSONAL INFORMATION

IV. HOW WE USE COOKIE AND SIMILAR TECHNOLOGIES

V. YOUR RIGHTS

VI. PROTECTION OF MINORS

VII. REVISION OF AND UPDATES TO THIS POLICY

VIII. CONTACT US

Policy Text

I. HOW WE COLLECT YOUR PERSONAL INFORMATION

In order to provide you with convenient and efficient services, we may collect your personal information through the following channels: [The information that you voluntarily provide, the information that you provide through browsers, emails, phone calls, and interaction with us, the transaction information of your purchase of services or products, and the necessary information that we legally obtain for fulfilling the contract (the carriers for the above information include but are not limited to written documents, electronic documents, telephone recordings, etc.)] The information collected through the above channels may include: [name, gender, birth date, certificate information (including ID card, passport, driver’s license, household register, military officer’s card, work permit, etc.), telephone number, email address, birthplace, household registration information, academic degree, work experience, employer information, job information, salary and welfare, family information, marriage and childbirth, medication and health-care, information about housing provident fund and social insurance, hobbies, travel information, payment information, etc.]. Please do not offer any sensitive personal information (such as race, religion, political stance, etc.) other than the information necessary for the service; however, such information may be collected unintentionally.

CIIC Shanghai only collects and uses your personal information for the following purposes described in this policy:

(I) To Provide You with the Services on the Company’s Official Website

Register as a user, member, or partner, or for business experience, etc. To create an account, you need to provide the following information: your cooperation details, name, gender, company, phone number, email address, etc. In the registration process, it will help us provide you with better service and experience if you provide the following additional information: birth date, document information, etc. However, failure to provide the above information will not affect the basic functions of the service. Uses of the above information you provided is authorized by you during the service period. When you deactivate your account, we will stop using and delete the above information.

(II) Corporate Business System (including but not limited to: CIIC e-home, Zhi Ling Tong, Zhi Yi Tong, Zhi Xiang Tong, etc.)

When we provide products and/or services through the corporate business system, we collect the necessary information, such as gender, ethnicity, political status, registered household address, residential address, health status, etc., to create an account. In addition, in order to guarantee the security of your account, we will verify your identity by sending an SMS verification code. You may also provide other personal information about you, which will help us to provide you with a personalized service experience. Failure to provide the above additional information will not affect you from using the basic functions of the corporate business system.

(III) Myjob500.com

Developed by CIIC Shanghai, Myjob500.com is a recruitment platform for college students. When you register, you will need to fill in your name and mobile phone number. Once your registration is successful, you may fill in the basic information of your college and major and upload your resume as you wish. Failure to provide the above information will not affect the basic functions of the service. Uses of the above information you provided is authorized by you during the service period. When you deactivate your account, we will stop using and delete the above information. (Video resumes uploaded by the user to the Myjob500.com database are usually stored for two years. Myjob500.com has the right to delete any video resume that has been stored for more than two years without notifying the user.)

II. HOW WE SHARE, TRANSFER, AND PUBLICLY DISCLOSE YOUR PERSONAL INFORMATION

(I) Sharing

We will not share your personal information with any company, organization, or individual other than CIIC Shanghai and its affiliates, with the following exceptions:

1. Sharing with explicit consent from you: We may share your personal information with others after obtaining your explicit consent.

2. We may share your personal information in compliance with laws and regulations or the mandatory requirements of the competent government authorities.

3. Sharing with authorized partners: Some of our services will be provided by authorized partners only for the purposes stated in this policy. We may share some of your personal information with our partners for better customer service and user experience. For example, we share your personal information with a logistics service provider to arrange delivery, or with our partner to provide services (with your personal information), or use your personal information for management and analysis (e.g. accounting, billing, auditing, payment confirmation, customer relationship management, etc.). We will only share your personal information for legal, legitimate, necessary, specific, and clarified purposes, and will only share the necessary personal information needed for providing the service. Our partners are not entitled to use the shared personal information for any other purposes. At present, our authorized partners include but not limited to political-legal organs, such as public security bureaus, procuratorates, courts, and their agencies, your employer or potential employer, and third-party organizations in business collaboration with CIIC Shanghai and its affiliates. For companies, organizations, and individuals with whom we share personal information, we will fully comply with our legal obligations and enter into a strict confidentiality agreement with them, which requires them to handle personal information in accordance with our instructions, this Privacy Policy, as well as any other relevant confidentiality and security measures. We only share the necessary personal information and are bound by the purposes stated in this Privacy Policy. If our authorized partner needs to change the purpose of processing your personal information, they shall ask for your authorization and consent.

(II) Transfer

We will not transfer your personal information to any company, organization or individual with the following exceptions:

1. Transfer with explicit consent from you: We will transfer your personal information to the other party with your explicit consent.

2. If the transfer of personal information is involved in the event of merger, acquisition, or bankruptcy liquidation, we will require the new company or organization that holds your personal information to continue to be bound by this Privacy Policy; otherwise, we will require the company and organization to ask for your authorization and consent again.

(III) Public Disclosure  

We will only publicly disclose your personal information under the following circumstances:

1. With your explicit consent;

2. Disclosure in accordance with law: We may publicly disclose your personal information following laws, legal procedures, litigation, or mandatory requirements of the competent authorities.

III. HOW WE PROTECT YOUR PERSONAL INFORMATION

(I) We have adopted industry-standard security measures to protect the personal information you provided from unauthorized access, public disclosure, use, and modification, damage, and loss. We take all reasonable and feasible steps to protect your personal information. For example, your browser is protected by SSL encryption when exchanging data (such as ID card and bank card information) with the service. Meanwhile, we provide http safe browsing mode for the official website. We use encryption to ensure the confidentiality of data. We use trusted protection mechanisms to protect data from malicious attacks. We deploy access control mechanisms to ensure that only authorized personnel have the access to the personal information. We also conduct security and privacy protection training courses to enhance employees’ awareness of the importance of personal information protection.

(II) We have obtained the following certification: ISO/IEC 27001:2013 and ISO29151:2017.

(III) Our data security capabilities: Our company’s internal network is protected by secure firewall. Any access to the internal network, including dial-in access, emails, and Internet access, is limited to authorized users. The computer accounts are protected by passwords, which are regularly examined to ensure security. Public domain hacking software is configured to test the internal security measures. Inspection records for access to and use of the Internet are saved.

(IV) We take all reasonable and feasible measures to ensure that irrelevant personal information is not collected. We only save your personal information for the period of time required to achieve the purposes stated in this policy, unless the period needs to be extended or permitted by law.

(V) The Internet is not an absolutely secure environment. Emails, instant messages, and communication with other users are not encrypted, therefore we strongly recommend that you do not send personal information in such ways. Please use complex passwords to help us to keep your account secure.

(VI) We regularly update and disclose security risks and assessment reports on security impacts on personal information. You may acquire them by sending email to [privacy@ciicsh.com] and we will reply to you within 30 working days.

(VII) The Internet is not 100% secure. We will do our best to ensure or guarantee the security of any information you send to us. If any damages to our physical, technical, or administrative protection facilities that result in unauthorized access, public disclosure, alteration, or destruction of the information and your legal rights being impaired, we will bear the corresponding legal obligations.

(VIII) In the event of an unfortunate personal information security incident, we will follow the requirements of laws and regulations and promptly inform you of: the basic situation and possible impact of the security incident, the countermeasures we have taken or will take, suggestions on how to initiatively defend and reduce risks, remedies for you, etc. We will promptly inform you of the incident by email, letter, phone call, notification, etc. In the event that it is difficult to inform the subject of personal information on a one by one basis, we will release announcements in a reasonable and effective manner. Meanwhile, we will report how the personal information security incident is handled in accordance with the requirements of the regulatory authorities.

For the users’ personal information collected within the territory of the People’s Republic of China, we will store it in China in accordance with laws and regulations. We will not keep your personal information exceeding the time necessary to achieve the processing purpose. Other than those stipulated in this Agreement and unless otherwise stated by laws and regulations, we will not sell or provide any personal information of any users to any third party.

IV. HOW WE USE COOKIES AND SIMILAR TECHNOLOGIES

(I) Cookies

To ensure the proper functioning of our site, we save small data files called cookies on your computer or apps on your mobile device. Cookies usually contain identifiers, site names, and some numbers and characters.

We do not use the cookies for any purpose other than those stated in this policy. You may manage or delete the cookies according to your preferences. For more information, please visit AboutCookies.org. You may clear all cookies saved on your computer. Most web browsers have the function to block cookies. However, by doing this, you will need to change the user settings yourself each time you visit our website. For more information about how to change your browser settings, please visit the official sites of browsers.

(II) Do Not Track

Many web browsers have a Do Not Track feature that sends Do Not Track requests to websites. Currently, major organizations for Internet standards have not yet established policies to regulate how websites shall respond to such requests. However, if your browser has enabled Do Not Track, all of our sites will respect your choice.

V. Your rights

In accordance with the relevant laws, regulations, and standards of China, and common practice of other countries and regions, we guarantee that you can exercise the following rights with respect to your personal information:

(I) Access to Your Personal Information

You have the right to access your personal information, unless otherwise required by laws and regulations. You may access the data in the following ways:

Account Information - If you want to access or edit profile information and payment information of your account, change your password, add security information, or deactivate your account, you can perform the action by clicking on the relevant service link.

Information retrieval - You can access or remove your search history, and view, modify, and manage other data on the company’s website.

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If you are unable to access your personal information via the above links, you can always mail us at our office address, call customer service hotline, or send an email to privacy@ciicsh.com. We will respond to your request within 30 days.

We will try our best efforts to provide you with any additional personal information that may generate during your use of our products or services, on the condition that it doesn’t require too many resources. If you want to access the data, please send us an email to privacy@ciicsh.com.

(II) Correct Your Personal Information

When you discover an error in your personal information that is processed by us, you have the right to require us to correct for you. You may file a correction request in the ways listed in “(I) Access to Your Personal Information”.

If you are unable to correct this personal information via the above links, you can always contact us via our web form or send an email to privacy@ciicsh.com. We will respond to your correction request within 30 days.

(III) Delete your personal information

You can make a request to us to delete your personal information in the following situations:

1. If we deal with personal information in violation of laws and regulations;

2. If we collect and use your personal information without your consent;

3. If we deal with personal information in violation of the agreement with you;

4. If you no longer use our products or services, or you deactivate your account number; or

5. If we no longer provide products or services to you.

Once we decide to respond to your delete request, we will also notify the entity which has obtained your personal information from us and require them to delete it promptly, unless otherwise required by laws and regulations, or the entity has obtained your independent authorization.

When you delete your information from our services, we may not immediately delete the corresponding information in the backup system, but will delete it when the backup is updated.

(Iv) Change the Scope of Your Authorization

Each business function requires some basic personal information in order to operate (see Part 1 of this policy). You may give or withdraw your authorization and consent at any time for the collection and use of additional personal information. When you withdraw your consent, we will no longer process the corresponding personal information. Your decision to withdraw your consent will not affect the personal information processing that was previously performed based on your authorization.

(V) Account Deactivation by a Subject of Personal Information 

You may deactivate your previously registered account at any time on the condition that it does not violate relevant laws and regulations or affect business operations. Once the account is deactivated, we will stop providing you with products or services, and will delete your personal information according to your request, unless otherwise required by laws and regulations.

(VI) A Subject of Personal Information Acquiring Copies of Personal Information

You have the right to obtain a copy of your personal information. On the premise of technical feasibility, such as data interfaces being matched, we can also directly transfer a copy of your personal information to your designated third party according to your request.

(Vii) Constraining Automatic Decision-making of Information Systems

In some business functions, we may rely solely on non-manual automatic decision-making mechanisms such as information systems and algorithms to make decisions. If such decisions affect your legal rights significantly, you have the right to request an explanation from us and we will provide appropriate remedies.

(VIII) Response to Your Above Requests

For security reasons, you may need to provide a written request or prove your identity in other methods. We may ask you to verify your identity before processing your request. We will respond within thirty days. If you are not satisfied, you can file a complaint by mails or letters to our correspondence address. In principle, we do not charge you for any reasonable request that you may have; however, we will charge a certain amount of fee for the repeated requests that are beyond reasonable limit. We may reject those requests that are unreasonably repetitive or requiring excessive technical support (e.g. developing a new system or fundamentally changing the existing practices), that poses risks to the legal rights of others, or are highly impractical (e.g. those involving information stored on backup tapes).

We will not be able to respond to your requests in the following situations that:

1. Are relevant to the controller of personal information fulfilling obligations stipulated by laws and regulations;

2. Are directly related to national security and national defense security;

3. Are directly related to public safety, public health, and major public interests;

4. Are directly related to criminal investigation, prosecution, trial and execution of judgments;

5. The controller of personal information has sufficient evidence to demonstrate the subjective malice or abuse of rights of the subject of personal information;

6. Serves the purpose of safeguarding important legal rights and interests such as life and property of the subject of personal information or other individuals while it is difficult to obtain the consent of the person;

7. Responding to the request of the subject of personal information will result in serious damage to the legitimate rights and interests of the subject of personal information or other individuals or organizations; and

8. Involves trade secrets.

Regarding your personal information, you are entitled to the rights according to applicable laws and regulations, including: obtaining a copy of the personal information you provide, correcting and deleting your personal information, withdrawing your consent to the use of personal information, and restricting our data processing activities of your personal information. You may contact us with the contact details listed in Section 8 to exercise the above rights. However, you acknowledge that there may be other legal justification that allow us to process the personal information you have provided.

VI. PROTECTION OF MINORS

Our products, websites and services are primarily for adults. Children shall not create their own user accounts without the consent of their parents or guardians.

For children’s personal information collected with parental consent, we will use or publicly disclose this information only when it is permitted by law, with the explicit consent of the parent or guardian, or for the need to protect the child.

Although there might be different definitions of children in different local laws and social conventions, we regard anyone under the age of 14 as a child.

If we discover any personal information about the child is collected without prior verifiable parental consent, we will try to delete the data as soon as possible.

VII. REVISION OF AND UPDATES TO THIS POLICY

Our privacy policy is subject to change.

We will not reduce your rights under this Privacy Policy without your explicit consent. We will post any changes to this policy on this page.

For major changes, we will provide more visible notifications (e.g., that for some services, we will send a notification via email stating the specific changes to the Privacy Policy).

The significant changes referred to in this policy include but not limited to:

1. Major changes to our service model, such as the purpose and type of processing personal information and the ways in which personal information is used;

2. Major changes to our ownership structure, organizational structure, etc., such as ownership changes as a result of business adjustments, bankruptcy mergers, etc.;

3. Changes to the main objects of personal information sharing, transfer, or public disclosure;

4. Major changes to your rights to participate in the processing of personal information and how they are exercised;

5. Changes to our departments responsible for personal information security, contact details, and complaint channels; and

6. When the personal information security impact assessment report indicates that there are multiple high risks.

This Policy is governed by laws of the People’s Republic of China. If its content conflicts with the relevant legal provisions, the legal provisions shall prevail. This policy is divisible, where the content that has been sentenced or ruled to be invalid does not affect the validity of other content. This policy was latest updated on January 1, 2019. We may revise this policy in due course, by which time we will post updates herein to keep you informed.

Please also visit [/ciicsh/dbcl/ystk/index.html] to keep up with our latest privacy policy.

We will also archive previous versions of this policy for your review.

VIII. CONTACT US

If you have any questions, comments, suggestions, complaints, or problems related to the protection of minors, welcome to contact us in the following ways: [email (privacy@ciicsh.com) and correspondence address (F45, Building #1, Grand Gateway, No. 1, Hongqiao Road, Xuhui District, Shanghai, 200030)]. We will respond to you within [15] working days after your identity is verified.