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.