Privacy Statement
This Statement was effective on 28 August 2023
1. Introduction
PricewaterhouseCoopers Zhong Tian LLP (hereafter referred to as “we”) are strongly committed to protecting your personal information. This Statement relates only to this Site. It does not relate to other technologies, products, services or sites of PwC Network Member Firms or any other party.
This Statement describes why and how we collect and process your personal information through this Site and provide information about your rights in relation to your personal information. This Statement also applies to personal information (including other individuals’) you provide to us through this Stie.
We only collect what we need and be transparent about why and how we process personal information. We may use the personal information provided in connection with this Site for any of the purposes described in this Statement or as otherwise stated at the point of collection.
You are visiting this Site as you are one of the following:
- Visitor
- Subscriber
2. Site Operator
The PwC firm operating this Site is the entity with primary responsibility for the protection of personal information and for ensuring compliance with applicable data protection laws.
Name of Site Operator and contact person are as follows:
PricewaterhouseCoopers Zhong Tian LLP
6/F, DBS Bank Tower, 1318 Lu Jia Zui Ring Road, Pudong New Area,
Shanghai 200120, China
Contact Number: +[86] (21) 2323 8888
If you are not receiving Services from the Site Operator, the PwC firm responsible for delivering services to you or your organization is the PwC firm providing you access to this Site.
3. Definition
In this Statement, we use the following terms:
“This Site” refers to the use of this Site to subscribe our newsletter, sign up to our events, or send an inquiry.
This Site is hosted in PwC server in Mainland China.
“Personal information” or “personal data” refers to various information related to an identified or identifiable natural person recorded electronically or by other means but does not include anonymized information. “Anonymization" refers to irreversible technical process that makes personal information subjects unidentifiable or unassociated.
"Personal information subjects” refers to natural person identified by or associated with personal information.
"Personal information processor/Data Controller" refers to an organization or individual that autonomously determines the purposes and means of personal information processing. This is equivalent to the definition of “Data User” under Personal Data (Privacy) Ordinance (Cap, 486) applicable to HKSAR and “Data Controller” under EU General Data Protection Regulation (“GDPR”) and other jurisdictions.
Processing of personal information” means processing of personal information includes, without limitation, the collection, storage, use, processing, transmission, provision, disclosure, and deletion of personal information. Processing under GDPR means any operation or set of operations which is performed on personal data or on sets of personal data, whether by automated means, such as collection, recording, organisation, transferring, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure, or destruction.
“PwC” refer to the list of PwC Member Firms operating in Mainland China, Hong Kong SAR, and Macau SAR responsible for delivering services to you or your organization and providing you access to this Site.
- Mainland China
- Hong Kong SAR
- Macau SAR
For a list of other PwC Network Member Firms, please see details at https://www.pwc.com/gx/en/about/corporate-governance/legal-entities.html.
Each member firm in the PwC network is a separate legal entity.
“Sensitive personal information” is personal information that once leaked or illegally used, may easily lead to the infringement of the personal dignity of a natural person or may endanger his personal safety or property, including information such as biometrics, religious belief, specific identity, medical health status, financial accounts, and the person’s whereabouts, as well as the personal information of a minor under the age of 14 years.
4. Collection of personal information
We may process your personal information for use of this Site. We may collect your personal information either directly from you or the organization contracted with PwC (e.g., your employer or authorized organization) authorizing you the use of this Site.
4.1 Categories of personal information collected
The personal information we collect includes:
(a) Necessary personal information
For you to use this Site, you will need to provide us or allow us to collect the following information:
Basic Business Function and Purpose of Processing |
Means of Processing
|
Necessary Personal Information |
Subscribe to e-newsletters - Send marketing materials to the subscribers |
Users subscribe and consent to receive marketing materials by submitting the 'Subscribe to e-newsletters' form. |
Name, job title, company name, email address |
Event registration - Register users for events, send event confirmation emails, and reminders |
Users input personal information through the 'Event registration' form, and this information will be used by the marketing department and other relevant departments to communicate with participants, confirm registration details, and send event confirmation emails and reminders. The information provided will help verify identities and tailor content based on participants' interests. |
Name, job title, company name, email address, contact number |
Contact us - Respond to the questions or feedback submitted through the 'Contact Us' form |
The contact information is essential for us to promptly respond to the questions or feedback the users have submitted through the 'Contact Us' form. |
Name, email address |
(b) Additional personal information
In order for you to use or for us to deliver the extended business function(s), the following additional personal information will need to be collected:
Extended Business Function(s) and Purpose of Processing |
Means of Processing
|
Additional Personal Information |
Event registration - Alternative contact information |
Users have the option to input alternative contact information if they prefer to be contacted through different means. |
Alternative contact information |
Contact us - Respond to the questions or feedback submitted through the 'Contact Us' form |
The additional information you have provided enables us to offer more accurate and relevant responses. |
Job title, company name, contact number |
Failure to provide us with such additional personal information will not negatively affect your use of the basic business function of this Site.
By using this Site and providing the above personal information to us, you confirm that you have read this Privacy Statement, and explicitly consent to the processing of personal information by us and any third-party recipients as set out in the Privacy Statement. We may rely on other legal grounds of processing to the extent permitted under applicable law.
(c) Sensitive personal information
We do not collect sensitive personal information through this Site unless such information is required to meet the specific purposes as stated above. Please do not provide any sensitive personal information unless you agree such information is necessary for specific purpose(s).
For Mainland China: For collection of sensitive persona information from individuals in Mainland China, we need to collect your separate consent to the extent your consent is necessary.
By providing sensitive personal information, you confirm that you provide your explicitly consent to the processing of sensitive personal information by us and any third-party recipients as set out in the Privacy Statement.
(d) Personal information of other individuals
If you are providing personal information of other individuals, please make sure that:
(i) the personal information is from a legitimate and lawful source.
(ii) the other individuals are aware of the categories of personal information and purpose(s) for collecting his/her personal information and all other relevant arrangement described in this Statement relating to the processing of personal information, and that he/she has consented to disclosure of personal information for processing by us.
We may contact you to inquire and confirm with you in relation to (i) and (ii) above. If you receive such an enquiry from us, please kindly assist and provide us with prompt response. We may have to discontinue your use of this Site if we are unable to obtain the verification needed.
5. Use of personal information
We use your provided personal information to provide you with our products or services, to communicate with you, to maintain the security of this Site, and to comply with applicable law. We use your provided personal information only when we have a legal basis to do so, including your prior consent where necessary.
We may also use the personal information collected above for the following purposes:
Use of Personal Information directly or reasonably related to the following purposes
- To provide the services requested by you or your organization.
- To provide you or your organization with use of this Site
- To communicate with you
- To maintain the security of this Site
- Authenticating the identity of users, authorising access to this Site (including preventing unauthorized access) and for other security-related purposes, including system security monitoring.
- To operate, administer, manage and improve this Site
- Administering this Site, troubleshooting issues and identifying areas of improvement.
- To maintain our administrative or client relationship management systems
- Where you are a business contact of ours, we may include your business contact details on our administrative or client relationship management systems (which may be located in secure data centres around the world), contact you in relation to the products or services and we may send you other material relevant to your interests (provided we have appropriate permission from you to do this, as required by laws).
- To analyze how this Site and associated services perform, we may analyze how this Site and associated services perform by reviewing the user data we capture.
- To enhance our user experience
- To comply with applicable law and regulation.
6. Third-party links
This Site may link to third-party sites via links which are not controlled by us and which do not operate under our privacy practices. When you access to third-party sites, our privacy practices no longer apply, and the third-party site provider is responsible for the personal information collected from you. We encourage you to review each third-party site's privacy policy before disclosing any personal information.
7. Our legal grounds for processing personal information
Applicable laws may require us to set out in this Statement the legal grounds on which we rely in order to process your personal information. In such cases, we rely on one or more of the following processing conditions:
(i) With your prior consent;
(ii) It is necessary for us to conclude or preform a contract with you;
(iii) It is necessary for us to perform the statutory duties or statutory obligations;
(iv) It is necessary for us to respond to a public health emergency or to protect the life, health and property safety of any individual;
(v) Such acts as news reporting and supervision by public opinions are carried out for the public interest, and the processing of personal information is within a reasonable scope;
(vi) it is necessary to process the personal information disclosed by you or other personal information that has been legally disclosed within a reasonable scope in accordance with the laws; and
(vii) Other circumstances prescribed by laws and administrative regulations.
The processing of personal information should be subject to your consent in accordance with relevant laws, however, your consent is not required under the circumstances set forth in Items (ii) to (vii) of the preceding paragraph.
9. International transfers of personal information
As PwC is a global network with member firms and third-party service providers located around the world. Your personal information may be transmitted and/or stored outside the country or region where you are located when we (as a PwC Network Member Firm) provide products or services to you. PwC Network Member Firms, our service providers or sub-processors they engage may use servers and other resources in various countries and territories to process your information.
Since we provide products or services through resources and servers all over the world, this means that after obtaining your separate authorized consent, your personal information may be transferred outside of the country where you use the Site to the extent permitted by laws.
For personal information collected from Mainland China:
In principle, the personal information we collect and generate in Mainland China will be stored within the Mainland China. With your consent, your personal information might be transmitted to or accessed from a jurisdiction outside of the country/region where you are located. Under such circumstances, we will ensure that your personal information will enjoy the same level of protection as it does in Mainland China.
We will satisfy the applicable condition(s) for cross border transfer (if any) required by applicable law.
We will enter contract or other legally effective documents with the recipients of personal information or implement other measures as required by laws of the People’s Republic of China to ensure that your personal information is adequately protected. For example, where applicable, we will ask for your separate consent to transfer personal information across borders, implement appropriate security measures for cross-border data transfer, conduct personal information protection impact assessment, and/or obtain the approval of competent authorities.
For personal information collected from European Economic Area (EEA) only:
Where we collect your personal information within the European Economic Area, transfer outside the European Economic Area will be only:
- to a recipient located in a country or region which provides an adequate level of protection for your personal information; and/or
- under an agreement which satisfies EU requirements for the transfer of personal information to data processors or data controllers outside the EEA, such as standard contractual clauses approved by the European Commission.
10. Security of personal information
We adhere to internationally recognized standards of technology and operational security to protect personal information from loss, misuse, alteration and destruction. Only authorized persons are provided access to personal information collected via this Site. These individuals have agreed to maintain the confidentiality of such information. We have a framework of policies and procedures in place covering data protection, confidentiality and security and regularly review the appropriateness of the measures we have in place to keep the personal information we hold secure.
Although we use appropriate security measures once we have received your personal information, the transmission of personal information over the Internet (including by email) is never completely secure. We endeavor to protect personal information, but we cannot guarantee the security of information transmitted electronically over the Internet.
Where a personal information security incident arises, we shall respond to the incident, assess the likely impact of the incident, and take necessary actions to bring the incident under control. Where necessary, we will report to the appropriate authority and notify you of the incident as may be required under applicable laws and regulations.
11. Cookies
When you use this Site, we may collect information about you and your use of the relevant Site, including through cookies and analytics tools. Cookies may be placed on your computer or device whenever you visit the Site. Cookies are small text placed on your device that assist us in providing a more customized experience by analyzing your use of this Site.
If you are concerned about cookies, most browsers permit individuals to decline cookies. In most cases, you can refuse cookies, however some functionality may be impaired.
You can always delete cookies if you wish via your browser’s setting.
12. Retention of personal information
It is our policy not to retain personal information longer than is necessary for the fulfilment of the purposes for which the information is to be used. We will retain personal information on our systems for as long as we need it, given the purposes for which it was collected, or as required to do so by applicable laws. Personal information may be held for longer periods where extended retention is agreed or are required by laws, regulations or professional standards and to establish, exercise or defend our legal rights. If the period necessary for the fulfilment of the purposes for which the information is to be used, agreed retention period, or legal retention period expires, we will erase the relevant personal information according to applicable law; if it is difficult to erase personal information technically, we will cease the processing of personal information other than storing and taking necessary security protection measures for such information.
13. Children
We are committed to protecting children’s privacy. This Site is not intentionally designed for or directed at children (i.e., minor under age of 14; “children” refers to the same group hereinafter), and we do not knowingly collect or store personal information about children. In the case of collecting personal information of a children in Mainland China, we will only use or publicly disclose such information if we have obtained explicit consent of their parent or guardian. We will protect the confidentiality and security of their personal information in accordance with relevant applicable laws and regulations.
14. Your rights in relation to your personal information
You may have certain rights under applicable laws and regulations in relation to the personal information we hold about you, including:
- Right to know and the right to decide on the processing of their personal information
- Right to restrict or refuse the processing of their personal information by others (except as otherwise provided by any law or administrative regulation)
- Right to access your personal information
You have the right to consult and duplicate the relevant personal information from us and request us to provide to you:
(i) a description of the type of personal information we hold about you, including a general account of its use;
(ii) the source of the above-mentioned personal information, as well as the purpose for which it is used;
(iii) what personal information has been made available to third parties, the identity or type of any third party who has obtained the above mentioned personal information, and the relevant information on agreements reached with third parties; and
(iv) you may also request a copy of certain categories of personal information
- Right to data portability
Where you request the transfer of your personal information which we have obtained to your designated personal information processor, we or third parties instructed by us would provide channels for such transfer if the conditions specified by the national cyberspace administration are met.
- Right not to subject automated decision making
Where a decision that has a major impact on your rights and interests is made by means of automated decision-making (if any), you have the right to request us to make explanations and to refuse to accept that we make decisions solely by means of automated decision-making.
- Right to request personal information processors to explain their personal information processing rules
- Right to request deletion of your personal information
Your right to request us to erase your personal information if:
(i) the processing purpose has been achieved or cannot be achieved, or it is no longer necessary to achieve the processing purpose;
(ii) the retention period described in Section 12 of this Statement has expired;
(iii) you withdraw consent; or
(iv) we collect or process personal information in violation of any law or administrative regulation or the agreement.
In such circumstances, if we receive your request to delete your personal information, we will also notify third parties whom we have transferred your personal information to delete personal information they hold about you. However, where the retention period provided by any law or administrative regulation has not expired, or it is difficult to realize the deletion of personal information technically, we would just cease the processing of personal information other than storing and taking necessary security protection measures for such information.
- Right to update/correct your personal information which is inaccurate or incomplete
Under certain circumstances permitted by applicable laws and regulations, we may refuse to accede to your requests above. In such circumstances, we will promptly notify you of the reasons for refusing to accede to your requests. We may charge a fee for your request to access your information, if permitted by applicable laws and regulations.
For security purposes, you may be required to provide written requests or prove your identification in other ways.
When requested, and provided that it is practical and commercially feasible to comply with the request, we will respond to your request after we have verified your identity:
(i) within 15 working days for personal information collected from Mainland China; or
(ii) such a time frame as prescribed under other applicable laws.
For personal information collected from European Economic Area (EEA) only:
If you are an individual based in the EEA and GDPR is applicable to PwC, you may be entitled to additional rights.
15. Deactivation of your account
Users of this Site may request their account be deactivated at any time by sending their request to pwc.cn.web.enquiry@cn.pwc.com. We will respond to your request within the time required under applicable laws.
16. Our Contacts
If you wish to submit a request to exercise your rights, under applicable privacy law, or have questions about how your information is handled at any time, or to make complaints, please send your request to our Privacy Team cn.dsar@cn.pwc.com.
Should you have any concerns with any matter in respect of this Statement, you may also approach members of the PwC team who is providing you or your organization with access to this Site to discuss.
Any unresolved dispute arising from or in connection with this Statement shall be resolved in accordance with the agreement (if applicable) between you/your organization and the PwC firm responsible for providing you with access to this Site.
17. Transfer of business
We reserve the right to transfer all data in its possession to a successor-in-interest to its business or assets in accordance with applicable law and regulation.
18. Changes to this Statement
We may update this Statement from time to time to comply with applicable laws and regulations or other legitimate purposes. We may also separately advise you about the changes. Subject to obtaining your explicit consent as may be required by applicable laws, the new modified Privacy Statement will apply from that revision date. Therefore, we encourage you to review this Statement periodically to be informed about how we are protecting your information.
