MAINLAND CHINA PRIVACY NOTICE
This China Privacy Schedule supplements our General Privacy Notice and applies where the Personal Information Protection Law of the People’s Republic of China, together with applicable PRC data protection, cybersecurity and data security laws, applies to our processing of personal information.
For the purposes of this Privacy Schedule, “personal information”, “sensitive personal information”, “processing” and “personal information processor” have the meanings given under applicable PRC law.
Otherwise, unless defined herein, capitalised terms in this Privacy Schedule shall be as defined in our General Privacy Notice.In particular, “Agency” and “Agency Group” refer to the specific agency, legal entity or group of entities responsible for the relevant processing, as described in the General Privacy Notice.
PERSONAL INFORMATION PROCESSOR
The personal information processor responsible for your personal information will usually be the Agency Group entity with which you or your organisation has a relationship, or which operates the relevant website, event or service.
You may contact us at: DPO@the-independents.com
Please see our General Privacy Notice for details of the relevant local entity or representative. Where required by PRC law, other details will be provided separately.
CATEGORIES OF PERSONAL INFORMATION WE PROCESS
We may process the following categories of personal information:
Category 1: Identity and contact information
Examples: Name, employer, job title, business address, email address, telephone number, social media/professional profile details
Category 2: Business communications
Examples: Emails, messages, meeting notes, call notes, event interactions and professional correspondence
Category 3: Profile and relationship information
Examples: Preferences, event attendance, interests, feedback, marketing preferences and relationship management notes
Category 4: Technical and usage information
Examples: IP address, browser type, device identifiers, website usage data, cookie and analytics information
Category 5: Compliance information
Examples: Information used for sanctions, anti-bribery, KYC, onboarding, supplier/client screening and related checks
Category 6: Financial and transaction information
Examples: Invoicing details, payment information, purchase order details and transaction records
Category 7: Other information
Examples: Information you or your organisation provide to us in the course of business
PURPOSES AND METHODS OF PROCESSING
We process personal information by electronic and, where necessary, manual means for the following purposes:
- managing our business relationship with you or your organisation;
- communicating with you;
- providing or receiving services;
- administering contracts, projects, accounts, procurement and payments;
- organising and managing events;
- conducting compliance, sanctions, anti-bribery, KYC and onboarding checks;
- sending business updates, invitations and marketing communications, where permitted;
- maintaining and improving our website, systems, services and operations;
- managing group administration, reporting and internal business operations;
- protecting our business, systems, staff, clients and partners;
- managing corporate transactions, reorganisations or integrations; and
- complying with legal, regulatory, tax, accounting and reporting obligations.
SENSITIVE PERSONAL INFORMATION
We do not usually seek to collect sensitive personal information from business contacts.
Where we need to process sensitive personal information, we will do so only where there is a specific purpose and sufficient necessity, and where required by PRC law we will obtain your separate consent.
Sensitive personal information may include information such as identification documents, financial account information, precise location data, health information, biometric information or other information treated as sensitive under PRC law.
CROSS-BOARDER TRANSFERS OF PERSONAL INFORMATION
Because we are part of an international group, your personal information may be transferred outside Mainland China to Agency Group entities, The Independents Group entities, clients, business partners and service providers in other jurisdictions, including the UK, EEA, United States, Hong Kong, Singapore, Japan, Korea, Switzerland, UAE and other countries in which we, our group companies, clients or service providers operate.
Where required by PRC law, we will implement an appropriate cross-border transfer mechanism, which may include:
- obtaining your separate consent;
- conducting a personal information protection impact assessment;
- entering into the PRC standard contract for cross-border transfer of personal information;
- completing a security assessment where required; and/or
- applying other lawful transfer mechanisms recognised under PRC law.
Where required by PRC law, we will provide additional details of overseas recipients, including their name or category, contact details, country or region, processing purposes, processing methods, categories of personal information, retention period and how you may exercise your rights.
The table set out in the Appendix to this Privacy Schedule provides an overview of the categories of overseas recipients to whom personal information may be transferred. Where PRC law requires more specific details of named overseas recipients, these will be provided separately or on request, as required by applicable law.
RETENTION
We retain personal information only for the period necessary for the purposes described in this Privacy Schedule and our General Privacy Notice, unless a longer retention period is required or permitted by law.
When personal information is no longer required, we will delete it, anonymise it or otherwise handle it in accordance with applicable PRC law and our retention policies.
AUTOMATED DECISION-MAKING
We do not use your personal information to make decisions based solely on automated processing that produce legal or similarly significant effects on you, unless we notify you separately and do so in accordance with applicable law.
Where we use automated tools, analytics or profiling in connection with our services, we will do so in accordance with applicable law. Where PRC law applies, you may have the right to request an explanation of automated decision-making and to refuse decisions made solely by automated decision-making where such decisions have a significant impact on your rights and interests.
YOUR PRC PRIVACY RIGHTS
Subject to applicable PRC law, you may have the right to:
- know and decide about the processing of your personal information;
- restrict or refuse processing;
- access and copy your personal information;
- correct or supplement inaccurate or incomplete personal information;
- request deletion of your personal information;
- withdraw consent where processing is based on consent;
- request an explanation of our personal information processing rules; and
- request transfer of your personal information where applicable legal conditions are met.
To exercise your rights, please contact: DPO@the-independents.com
We may need to verify your identity before responding to your request.
Updated: April 2026
APPENDIX
Cross-border transfers of personal information:
OVERSEAS RECIPIENT
Agency Group companies and The Independents Group entities outside Mainland China
UK, EEA, United States, Hong Kong, Singapore, Japan, Korea, Switzerland, UAE and other jurisdictions where group entities operate
Purpose of Transfer:
Group administration, business relationship management, service delivery, reporting, finance, legal, compliance, IT support, management oversight and internal operations
Categories of Personal Information:
Identity and contact information, business communications, profile and relationship information, technical and usage information, compliance information, financial and transaction information and other relevant business information
Processing Method:
Access, storage, use, organisation, analysis, transmission, hosting, support and reporting
Retention Period:
As described in our General Privacy Notice, this Privacy Schedule and our applicable retention policies; generally for as long as necessary for the relevant business, legal, compliance, contractual or operational purpose
How to Exercise Rights:
DPO@the-independents.com
OVERSEAS RECIPIENT
IT, hosting, cloud, CRM, email, collaboration and system administration providers
UK, EEA, United States, Hong Kong, Singapore and other jurisdictions depending on the provider and system used
Purpose of Transfer:
Hosting, storage, IT support, system administration, cybersecurity, CRM management, email communications, collaboration tools and business continuity
Categories of Personal Information:
Identity and contact information, business communications, technical and usage information, profile and relationship information and other information stored in relevant systems
Processing Method:
Hosting, storage, access, transmission, support, maintenance, security monitoring and troubleshooting
Retention Period:
For the duration of the relevant service and thereafter as required by contract, law or applicable retention policy
How to Exercise Rights:
DPO@the-independents.com
OVERSEAS RECIPIENT
Clients, brands, event partners, production partners and business partners
Relevant client or partner jurisdictions, which may include the UK, EEA, United States, Hong Kong, Singapore, Japan, Korea, UAE and other event or project locations
Purpose of Transfer:
Delivering services, managing campaigns, events, productions, collaborations, guestlists, logistics, reporting, client communications and business relationships
Categories of Personal Information:
Identity and contact information, business communications, profile and relationship information, event or project information, logistics information and other information relevant to the specific service
Processing Method:
Access, use, transmission, organisation, analysis, reporting and project administration
Retention Period:
For the duration of the relevant project, event, campaign or business relationship and thereafter as required for legal, contractual, audit, reporting or dispute purposes
How to Exercise Rights:
DPO@the-independents.com
OVERSEAS RECIPIENT
Event, travel, hospitality, logistics and production service providers
Event, travel or production destination countries and provider locations, which may include the UK, EEA, United States, Hong Kong, Singapore, Japan, Korea, UAE and other jurisdictions
Purpose of Transfer:
Event administration, travel booking, accommodation, transport, hospitality, access control, security, production support and related logistics
Categories of Personal Information:
Identity and contact information, travel information, passport or identification details where necessary, accommodation details, event attendance, dietary/accessibility information where relevant and other logistics information
Processing Method:
Access, use, transmission, booking, coordination, storage and support
Retention Period:
For the duration of the relevant booking, event, travel, production or logistics purpose and thereafter only as required for legal, audit, security, insurance or dispute purposes
How to Exercise Rights:
DPO@the-independents.com
OVERSEAS RECIPIENT
Finance, accounting, payment, banking and professional services providers
UK, EEA, United States, Hong Kong, Singapore, Switzerland and other jurisdictions depending on the provider
Purpose of Transfer:
Payments, invoicing, accounting, audit, tax, banking, legal, insurance, compliance and professional advisory services
Categories of Personal Information:
Identity and contact information, financial and transaction information, invoices, payment details, purchase order information, tax/accounting information and relevant business communications
Processing Method:
Access, use, storage, transmission, review, reporting, audit and professional advice
Retention Period:
For the period required for payment, accounting, tax, audit, legal, regulatory and dispute purposes, in accordance with applicable law and our retention policies
How to Exercise Rights:
DPO@the-independents.com
OVERSEAS RECIPIENT
Compliance screening, sanctions, anti-bribery, KYC and onboarding providers
UK, EEA, United States and other jurisdictions depending on the provider
Purpose of Transfer:
Supplier/client screening, sanctions checks, anti-bribery checks, onboarding, compliance, risk management and regulatory recordkeeping
Categories of Personal Information:
Identity and contact information, employer/company information, role/title, due diligence information, screening results and relevant compliance information
Processing Method:
Access, screening, matching, review, storage, reporting and transmission
Retention Period:
For as long as necessary for compliance, legal, audit, regulatory, risk management and dispute purposes
How to Exercise Rights:
DPO@the-independents.com
OVERSEAS RECIPIENT
Professional advisers, regulators, courts, public authorities and law enforcement bodies
Relevant jurisdictions depending on the matter
Purpose of Transfer:
Legal advice, audit, insurance, regulatory compliance, litigation, investigations, enforcement, reporting and protection of rights
Categories of Personal Information:
Relevant categories of personal information necessary for the relevant legal, regulatory, audit, insurance, investigation or dispute purpose
Processing Method:
Access, use, disclosure, transmission, review, storage and professional analysis
Retention Period:
For as long as required or permitted by applicable law, professional obligations, regulatory requirements, litigation hold, audit or dispute purposes
How to Exercise Rights:
DPO@the-independents.com
OVERSEAS RECIPIENT
Parties involved in corporate transactions, reorganisations, integrations, investments or asset sales
Relevant jurisdictions depending on the transaction
Purpose of Transfer:
Due diligence, transaction planning, corporate integration, restructuring, investment, merger, acquisition or asset sale
Categories of Personal Information:
Identity and contact information, business communications, financial and transaction information, contractual information, compliance information and other information relevant to the transaction
Processing Method:
Access, review, analysis, disclosure, storage, transmission and integration planning
Retention Period:
For the duration of the transaction process and thereafter as required for legal, regulatory, audit, corporate recordkeeping or dispute purposes
How to Exercise Rights:
DPO@the-independents.com
OVERSEAS RECIPIENT
The Independents Group entities outside Mainland China
UK, EEA, United States, Hong Kong, Singapore, Japan, Korea, Switzerland, UAE and other jurisdictions where group entities operate
Purpose of Transfer:
Group administration, business relationship management, service delivery, reporting, finance, legal, compliance, IT support, management oversight and internal operations
Categories of Personal Information:
Identity and contact information, business communications, profile and relationship information, technical and usage information, compliance information, financial and transaction information and other relevant business information
Processing Method:
Access, storage, use, organisation, analysis, transmission, hosting, support and reporting
Retention Period:
As described in our General Privacy Notice, this Privacy Schedule and our applicable retention policies; generally for as long as necessary for the relevant business, legal, compliance, contractual or operational purpose
How to Exercise Rights:
DPO@the-independents.com
OVERSEAS RECIPIENT
IT, hosting, cloud, CRM, email, collaboration and system administration providers
UK, EEA, United States, Hong Kong, Singapore and other jurisdictions depending on the provider and system used
Purpose of Transfer:
Hosting, storage, IT support, system administration, cybersecurity, CRM management, email communications, collaboration tools and business continuity
Categories of Personal Information:
Identity and contact information, business communications, technical and usage information, profile and relationship information and other information stored in relevant systems
Processing Method:
Hosting, storage, access, transmission, support, maintenance, security monitoring and troubleshooting
Retention Period:
For the duration of the relevant service and thereafter as required by contract, law or applicable retention policy
How to Exercise Rights:
DPO@the-independents.com
OVERSEAS RECIPIENT
Clients, brands, event partners, production partners and business partners
Relevant client or partner jurisdictions, which may include the UK, EEA, United States, Hong Kong, Singapore, Japan, Korea, UAE and other event or project locations
Purpose of Transfer:
Delivering services, managing campaigns, events, productions, collaborations, guestlists, logistics, reporting, client communications and business relationships
Categories of Personal Information:
Identity and contact information, business communications, profile and relationship information, event or project information, logistics information and other information relevant to the specific service
Processing Method:
Access, use, transmission, organisation, analysis, reporting and project administration
Retention Period:
For the duration of the relevant project, event, campaign or business relationship and thereafter as required for legal, contractual, audit, reporting or dispute purposes
How to Exercise Rights:
DPO@the-independents.com or, where appropriate, the relevant client or partner identified to you
OVERSEAS RECIPIENT
Event, travel, hospitality, logistics and production service providers
Event, travel or production destination countries and provider locations, which may include the UK, EEA, United States, Hong Kong, Singapore, Japan, Korea, UAE and other jurisdictions
Purpose of Transfer:
Event administration, travel booking, accommodation, transport, hospitality, access control, security, production support and related logistics
Categories of Personal Information:
Identity and contact information, travel information, passport or identification details where necessary, accommodation details, event attendance, dietary/accessibility information where relevant and other logistics information
Processing Method:
Access, use, transmission, booking, coordination, storage and support
Retention Period:
For the duration of the relevant booking, event, travel, production or logistics purpose and thereafter only as required for legal, audit, security, insurance or dispute purposes
How to Exercise Rights:
DPO@the-independents.com