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Privacy Policy

This website provides information about our Company. This Privacy Notice sets out how we use and protect any information we collect through this website.

1. Introduction

No Personal Data will be proactively collected from you by this website, unless for ad-hoc activities or ad-hoc function incorporated to the website from time to time. Personal Data, if collected in the above scenarios, will be only used for specific and limited purposes. Once collected, Personal Data will not be used for a different or incompatible purpose without your consent. We, the Company, is the data controller of the data collected through this website.

We take the protection of data privacy very seriously. All Personal Data collected through the website, if any, will be treated as strictly confidential and will only be used as set out in this Privacy Notice. The applicable data protection laws shall be respected in full.

Therefore, please read this Privacy Notice thoroughly. If you disagree with the way Personal Data will be used, please do not use this website or provide your Personal Data through this website.

2. Purpose of data collection

The website may collect Personal Data in the scenarios and/or for the purposes as follows: 1) for the purpose to get in contact with the user promptly and efficiently when there is necessity to answer the questions initiated by the user; 2) for the purpose to categorize the users and launch the relevant activities efficiently, in the scenario that the website operates ad-hoc activities, e.g. user survey; 3) for the purpose to realize the functions efficiently, in the scenario that the website incorporates ad-hoc functions, e.g. function that user may subscribe information from the Company. The above purposes will be referred to collectively as the “Express Purposes” hereinafter.

3. What Personal Data do we collect and process?

We may collect different Personal Data according to the different requirements for specific project or function, based on the Express Purposes, including without limitation to name, address, phone number, email address, gender, age, etc. We will inform you what exact Personal Data we collect and the use and way of process to such Personal Data, when we launch the specific project or function.

4. What legal ground(s) do we rely on?

Where Personal Data is collected from you through the website, we will obtain your consent. Please note that you are under no obligation to provide your Personal Data under the above scenarios and purposes. You always have a choice concerning whether or not you provide Personal Data, and you can withdraw or revoke your consent to our use of Personal Data at any time.

5. With whom do we share Personal Data?

In the premises that for the Express Purpose only, the website will, when launching a specific project or function, inform you who will receive the Personal Data from us, and obtain your explicit consent to such sharing, if it is necessary to provide the Personal Data to a third party to realize the Express Purpose (e.g. the user survey is operated by a third party, or, the information subscribed by the user will be provided by a third party, etc.).

6. Viewing, Editing, Updating or Deletion of your Personal Data

Please contact with the department or person as specified at the end of this policy, if you want to see any Personal Data stored about you in our records. We will honor your legal right to view your Personal Data in accordance with applicable privacy law. If you think that any of the Personal Data collected through the website is incorrect, confusing or incomplete, please contact the department or person as specified at the end of this policy. You may also ask us to erase, restrict or port your Personal Data and you may tell us if you object to our use of your Personal Data.

Personal Data will be stored and protected by us in accordance with our applicable data retention requirements and corporate policies.

7. Data Security

We strictly keep the Personal Data confidential. We use a variety of methods, such as firewalls, intrusion detection software and manual security procedures, to secure your data against loss or damage and to help protect the accuracy and security of Personal Data and to prevent unauthorized access or improper use. If you think that the website or any Personal Data is not secure or that there has been unauthorized access to the website or your Personal Data, please contact the department or person as specified at the end of this policy immediately.

8. Data Transfer

We are a subsidiary ultimately controlled by a multinational Groupe whose headquarter bases in Europe. Thus, the Personal Data collected through the website may be transferred, for Express Purposes pursuant to circumstances, to Europe or other territory where centralized services are provided to the Groupe’s affiliated companies from (“Overseas”). We ensure all data transfers comply with applicable legal requirements (for example under intercompany agreements with appropriate contractual protections). Should you wish to know more about how data is protected or wish to request a copy of the contractual protections please contact our chief privacy officer to his email address as listed at the end of this policy.

9. Special Circumstances. Silent Consent. Consequence of Rejection

9.1 We will not obtain your consent for collecting, using or processing your Personal Data outside of the informed purposes, method or scope in the scenarios as follows (the “Special Circumstances”):

a) the special circumstances provided by applicable laws, e.g. to protection for the public safety, emergency actions, etc.; b) for the purpose of academic research or public benefits; c) the enforcement action by the government administrative authorities in accordance with laws; d) the decision, ruling or judgement made by judicial authorities in accordance with laws.

9.2 If you still voluntarily participate the ad-hoc activities or use the ad-hoc functions of this website after we have informed you about the purpose, method and scope of collecting, using, processing your Personal Data and/or that we will provide your Personal Data to third parties and/or that we will transfer your Personal Data overseas, the behaviors of your participation or/and usage shall be deemed as your consent to our collection, use and processing of your Personal Data, and/or our provision of your Personal Data to the third parties, and/or our transfer of your Personal Data overseas.

9.3 You may not participate or continue participating the ad-hoc activities of the website, or may not use or continue using the ad-hoc functions of the website, if you refuse our collection, use or processing of your Personal Data, or/and refuse the provision of your Personal data to third parties, or/and refuse the transfer of your Personal Data overseas, or you withdraw or revoke the consent you have made.

10. Use of cookies or other tracking technology

A cookie is a small file which is placed on your computer's hard drive. If you choose to accept cookies (see below), the file is added and the cookie helps analyze web traffic or lets you know when you visit a particular site. Cookies allow web applications to respond to you as an individual. The web application can tailor its operations to your needs, likes and dislikes by gathering and remembering information about your preferences. We use traffic log cookies to identify which pages are being used. This helps us analyze data about web page traffic and improve our website in order to tailor it to customer needs. We only use this information for statistical analysis purposes and then the data is removed from the system. Overall, cookies help us provide you with a better website, by enabling us to monitor which pages you find useful and which you do not.
You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. This may prevent you from taking full advantage of the website. A cookie is a small file which is placed on your computer's hard drive. If you choose to accept cookies (see below), the file is added and the cookie helps analyze web traffic or lets you know when you visit a particular site. Cookies allow web applications to respond to you as an individual. The web application can tailor its operations to your needs, likes and dislikes by gathering and remembering information about your preferences.

We use traffic log cookies to identify which pages are being used. This helps us analyze data about web page traffic and improve our website in order to tailor it to customer needs. We only use this information for statistical analysis purposes and then the data is removed from the system.

Overall, cookies help us provide you with a better website, by enabling us to monitor which pages you find useful and which you do not.

You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. This may prevent you from taking full advantage of the website.

11. Notification of changes

Should we wish to change this Privacy Notice, if you have already provided Personal Data through this website we will contact you to inform you of the new Privacy Notice and, in some circumstances, we may need to obtain your consent to the changes. In other circumstances, any such changes to this Privacy Notice will be promptly communicated on this page and you should check back to see whether there are any changes. Continued use of the website after a change in the Privacy Notice indicates your acknowledgement and acceptance of the use of Personal Data in accordance with the amended Privacy Notice.

12. Definitions

“Personal Data” means any information relating to an identified or identifiable natural person; an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person. “Processing” means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction. “Data Transfer” means the one-off or continuous provision of the Personal Data that collected or generated from the local territory, to the oversea authorities, organizations or individuals, by means of direct transmission, business operation or service provision etc. through network or other ways. “Consent” includes implied consent and explicit consent. “Implied consent” means the action or omission of action of the data subject that can be deemed as consent in the situation that the data subject does not expressly object; “Explicit consent” means the expressly consent made by the data subject, the evidence of which is well kept. “Data Subject” means an identified or identifiable natural person that the information is relating to.

13. Further Information

If you wish to browse your Personal Data that you have provided, or you find your Personal Data inaccurate, misleading, incomplete and necessary to be rectified, or you consider the website is unsecure so that your Personal Data must be deleted, or you believe there is unauthorized access to the website or your Personal Data, please contact Annie.yang@cn.leoburnett.com. If you consider that we are not complying with this Privacy Notice or if you have any questions in relation to this Privacy Notice, please contact the Chief Data Privacy Officer of Publicis Groupe privacyofficer@publicisgroupe.com. You may also lodge a formal complaint with your competent data protection authority.

Leo Burnett China Version: December 1st, 2017