AustCham Shanghai Privacy Statement
Last updated 17 March 2022
Ao Shang Hui Consulting Ltd (together “AustCham Shanghai”, “we”, “our” and “us”) is committed to respecting and protecting your privacy. We comply with the Personal Information Protection Law (“PIPL”).
For the purposes of the PIPL, AustCham Shanghai is deemed to be the personal information
handler and as such is responsible for the collection and processing of your personal information.
1. Collection and use of personal information
For the purposes of the PIPL, personal information is all information related to identified or identifiable natural persons. This includes information which may not identify a natural person, but is still related to an identified person.
1.1 What information we collect
We obtain personal information about you if you choose to provide it - for example to contact mailboxes or to register for certain events and services. In some cases, you may have previously provided your personal information to AustCham Shanghai (if, for example, you are a former employee). If you choose to register or login in to the AustCham Shanghai website using a third party single sign-in service that authenticates your identity and connects your social media login information (e.g., WeChat or QQ) with AustCham Shanghai, we will collect any information or content needed for the registration or log-in that you have permitted the social media provider to share with us, such as your name and email address for the purposes above mentioned. Other information we collect may depend on the privacy settings or policy of the applicable service.
By registering and/or submitting personal information to AustCham Shanghai, you are also acknowledging that AustCham Shanghai may use this information in accordance with this Privacy Statement. Your personal information is not used for other purposes, unless we obtain your permission, or unless otherwise required or permitted by law. Where you register or login using a third party single user sign-in we may also recognise you as the same user across any different devices you use and personalise your user experience.
In some cases where you have registered for certain services we may store your email address temporarily until we receive confirmation of the information you provided via an email (i.e. where we send an email to the email address provided as part of your registration to confirm a subscription request) or required by the applicable law.
We may also collect information from in person discussions, telephone conversations, and through non-electronic communications (i.e., collection through means other than AustCham Shanghai’s online systems).
1.2 The legal grounds on which we process your personal information
AustCham Shanghai generally collects only the personal information necessary to fulfil your request. Where additional, optional information is sought, you will be notified of this at the point of collection.
When we process your personal information, we will rely on one of the following processing conditions permitted under the PIPL:
• Your consent: we may ask you for specific and separate permission to process some of your personal information, and we only process your personal information in this way if you agree to us doing so. You may withdraw your consent at any time by contacting AustCham Shanghai at email@example.com;
• Performance of a contract: this is when the processing of your personal information is necessary in order to perform our obligations under a contract entered with you; and
• Legal obligation: this is when we are required to process your personal information in order to comply with a legal obligation, such as records for tax purposes or providing information to a public body or law enforcement agency.
In limited circumstances, AustCham Shanghai may collect sensitive personal information when the relevant individuals voluntarily provide us with this information (for example, where we require specific information for an event hosted by us that you are attending) or where such information is required or permitted to be collected by law, or to fulfil our obligations under a contract. Sensitive information includes, but is not limited to, personal information on biometric characteristics, religious beliefs, specifically-designated status, medical health, financial accounts, individual location tracking and personal information of minors under the age of fourteen. You should not provide yours or any third parties’ sensitive personal information to AustCham Shanghai unless we separately notify you (and these third parties) and you (and these third parties) have given us your (and these third parties’) explicit consent for AustCham Shanghai to use or process your (and these third parties’) sensitive personal information for legitimate and necessary business purposes and you (and these third parties) have also consented for us to transfer such sensitive personal information to third parties as may be necessary, and to store such sensitive personal information. If you have any questions about the provision of sensitive information, please contact AustCham Shanghai at firstname.lastname@example.org.
1.3 Automatic collection of personal information
An IP address is a number assigned to your computer whenever you access the internet. It allows computers and servers to recognise and communicate with one another. IP addresses accessing our website are anonymised and we are not able to use this information for analysis purposes.
Cookies may be placed on your computer or internet-enabled device whenever you visit us online. This allows the site to remember your computer or device and serves the purposes notified in this Privacy Statement. You may delete cookies from your device at any time.
Further information about managing cookies can be found in your browser's help file or through sites such as www.allaboutcookies.org.
Below is a list of the types of cookies used on our web site:
Other third party tools and widgets may be used on our individual web pages to provide additional functionality. Use of these tools or widgets may place a cookie on your device to make their service easier to use, and ensure your interaction is displayed on our webpages properly.
Cookies by themselves do not tell us your email address or otherwise identify you personally. In our analytical reports, we may obtain other identifiers including IP addresses, but this is for the purpose of identifying the number of unique visitors to our web sites and geographic origin of visitor trends, and not to identify individual visitors.
By navigating on our website or entering your login details to access areas reserved or members, you agree that we can place these cookies on your computer or internet enabled device.
AustCham Shanghai uses Google Analytics. More information about how Google Analytics is used by AustCham Shanghai can be found here: https://www.google.com/analytics/terms/us.html
2. Sharing and transfer of personal information
2.1 Transfers to third parties
We do not share personal information with third parties, except as necessary for our legitimate professional and business needs, to carry out your requests, and/or as required or permitted by law. This would include third party service providers for the provision of HR services, government bureaus and agencies, event management and member communications/ surveys. We ensure that all third parties comply with the PIPL and we only share personal information that allows them to provide the services and/or comply with statutory requirements.
2.2 Transfers of personal information outside of the People’s Republic of China
In certain circumstances, and to the extent permitted by law, we may transfer personal information submitted by you to third party organisations outside of the People’s Republic of China for the purposes of providing services to you, meeting contractual obligations or to meet statutory requirements.
By submitting personal information via online systems, you are explicitly consenting to this transfer and/or storage of the personal information across boarders for the purpose of this clause 2. You agree and warrant to notify these individuals of such cross boarder transfer and obtain separate consent from these individuals, whenever required under the applicable laws, prior to the submission of such personal information to AustCham Shanghai. By consenting to this Privacy Statement you confirm that explicit consent has been obtained from the relevant individuals.
In general, you are not required to submit any personal information to AustCham Shanghai, but we may require you to provide certain personal information in order for you to receive additional information about our services and events.
AustCham Shanghai may also ask for your permission for certain uses of your personal information, and you can agree to or decline those uses. If you opt-in for particular services or communications, such as an e-newsletter, you will be able to unsubscribe from a service or communication. If you decide to unsubscribe from a service or communication, we will try to remove your information promptly, although we may require additional information before we can process your request.
4. Your rights
You have certain rights regarding how we use and keep your personal information. These are:
• Right of knowledge, decision, restriction, objection and recession - subject to laws and administrative regulations, you have the right to know, decide and object to the personal information we hold on you and the manner in which we process that personal information.
• Right to access, copy and portability - you have the right to request access or a copy of the personal information we hold on you, such information to be provided to you in a timely manner. You also have the right to request that we transfer your personal information to a designated personal information handler.
• Right to rectification - in the event that the personal information we hold on you is found to be inaccurate or incomplete, you have the right to request a correction and/or provide supplementary personal information. Such requests will be verified, and corrections and/or the additions of supplemental personal information, shall be made in a timely manner.
• Right to deletion - we shall delete the personal information that we hold on you in the following circumstances:
‣ where the purpose of processing has been achieved or is no longer necessary or is no longer necessary to achieve the purpose of processing;
‣ where AustCham Shanghai stops providing services to you, or the retention period has expired;
‣ if you withdraw your consent for processing of your personal information;
‣ if AustCham Shanghai processes personal information in violation of laws, administrative regulations or our agreement with you;
‣ any other circumstances as prescribed be laws and and administrative regulations.
You have the right to request deletion in the event that the personal information we hold on you has not been deleted in accordance with the above circumstances.
Please note that in certain circumstances, deletion of personal information may impact on our ability to continue to provide a service to you and/or comply with contractual requirements.
We do not process personal information for the purposes of automated decision making.
You can make a request to or exercise these rights by by contacting AustCham Shanghai at email@example.com.
5. Data security and integrity
AustCham Shanghai has reasonable security policies and procedures in place to protect personal information from unauthorised loss, misuse, alteration, or destruction. Despite AustCham Shanghai’s best efforts, however, security cannot be absolutely guaranteed against all threats. To the best of our ability, access to your personal information is limited to those who have a need to know. Those individuals who have access to the data are required to maintain the confidentiality of such information.
We also make reasonable efforts to retain personal information only for so long as the information is necessary to comply with an individual's request or until that person asks that the information be deleted.
6. Changes to this statement
AustCham Shanghai may modify this Privacy Statement from time to time to reflect our current privacy practices. When we make changes to this statement, we will revise the “updated” date at the top of this page. We encourage you to periodically review this Privacy Statement to be informed about how AustCham Shanghai is protecting your information.
7. Questions and enforcement
AustCham Shanghai is committed to protecting the online privacy of your personal information. If you have questions or comments about our administration of your personal information, please contact us at firstname.lastname@example.org. You may also use this address to communicate any concerns you may have regarding compliance with our Privacy Statement.
We will acknowledge your email within 14 days and seek to resolve your concern within one month of receipt. Where the concern is complex or we have a large volume of concerns, we will notify you that the concern will take longer than one month to resolve, and we will seek to resolve your concern within three months of the concern being first raised. We may accept your concern (and in that case implement one of the measures set out in the ‘Your Rights’ section above), or we may reject your concern on legitimate grounds.