Data Privacy

Data Protection Privacy Policy

This Privacy Policy describes how our Group collects, uses and shares the information you provide to us and the information we collect in the course of operating our business and our websites.

We may revise this Policy at any time by amending this page. You are expected to check this page from time to time to take notice of any changes we make, as they are binding on you.

The information that we collect and where we get it from

“Personal information” is any information that can be used to identify you or that we can link to you and which we have in our possession or control.

We will collect and process the following personal information about you:

Information that you provide to us

We will process personal information that you give to us including when you email us or contact us through various channels as follows:

Website visit: when you contact us with queries or respond to our communications on our website the personal information you provide may include your name, email address and information about you or your business.
Seminars or other events: when you attend seminars or other events that we meet each other the personal information you provide may include your name, telephone number, email address and information about you or your business.
In connection with our provision of services: if you are a client of our Group you will provide us with personal information when you or the company you represent becomes a client. If you are not a client we may collect or receive your personal information because you are involved in one of our client’s matters.

Information we otherwise collect about you

We will also collect information about when you use our services or when we otherwise interact or correspond with you.

Information we obtain from other sources

If we collect or receive your personal information in the context of our provision of professional services, we might receive information from third parties such as other parties relevant to the services we are providing (e.g. counterparties in transactions) and others such as regulators and authorities. Those information could include your name, contact details, and other information relevant to the professional services that we are providing to our client.

How we use the information we collect

We may do the following with your personal information:

1. use it to provide professional services to the relevant client

2. use it to engage in marketing and business development activity in relation to our professional services. This may include sending you newsletters, company updates, marketing communications and other information that may be of interest to you

3. to comply with legal and regulatory obligations that we have to discharge

4. use it to establish, exercise or defend our legal rights or for the purpose of legal proceedings

5. record and monitor your use of our websites or our other online services for our business purposes which may include analysis of usage, measurement of site performance and generation of marketing reports

6. use it for our legitimate business interests, such as undertaking business research and analysis, managing the operation of our websites and our business

7. use it to look into any complaints or queries you may have, and

8. use it to prevent and respond to actual or potential fraud or illegal activities.

Grounds for using your personal information

We rely on the following legal grounds to process your personal information, namely:

Consent – we may need your consent to use your personal information. You can withdraw your consent by contacting us.
Performance of a contract – we may need to collect and use your personal information to enter into a contract with you or to perform our obligations under a contract with you.
Legitimate interest – we may use your personal information for our legitimate interests, some examples of which are given above.
Compliance with law or regulation – we may use your personal information as necessary to comply with applicable law/regulation.

How we share information with third parties

We share personal information within our Group. We may also share your personal information outside our Group. This may include:

Third party agents/suppliers or contractors, bound by obligations of confidentiality, in connection with the processing of your personal information for the purposes described in this Policy. This may include, but is not limited to, IT and communications service providers.
Third parties relevant to the professional services that we provide. This may include, but is not limited to, counterparties to transactions, other professional service providers, regulators, authorities, governmental institutions and stock exchanges.
To the extent required by law, regulation or court order, for example, if we are under a duty to disclose your personal information in order to comply with any legal obligation.

Your information may be transferred and stored in locations outside the European Economic Area (EEA), including countries that may not have the same level of protection for personal information. When we do this, we will ensure it has an appropriate level of protection and that the transfer is lawful. We may need to transfer your information in this way to carry out our contract with you, to fulfill a legal obligation, to protect the public interest and/or for our legitimate interests. In some countries the law might compel us to share certain information, e.g. with tax authorities. Even in these cases, we will only share your information with people who have the right to see it.

You can obtain more details of the protection given to your information when it’s transferred outside the EEA by contacting us.

Keeping your information and information security

How long we hold your personal information for will vary and will depend principally on:

the purpose for which we are using your personal information – we will need to keep the information for as long as is necessary for the relevant purpose, and
legal obligations – laws or regulation may set a minimum period for which we have to keep your personal information.

We will ensure that the personal information that we hold is subject to appropriate security measures.

Your choices and rights

You have a number of legal rights in relation to the personal information that we hold about you and you can exercise your rights by contacting us.

These rights include:

Obtaining information regarding the processing of your personal information and access to the personal information which we hold about you.
Please note that there may be circumstances in which we are entitled to refuse requests for access to copies of personal information. In particular, information that is subject to legal professional privilege will not be disclosed other than to our client and as authorised by our client.
Requesting that we correct your personal information if it is inaccurate or incomplete.
Requesting that we erase your personal information in certain circumstances. Please note that there may be circumstances where you ask us to erase your personal information but we are legally entitled to retain it.
Objecting to, and requesting that we restrict, our processing of your personal information in certain circumstances. Again, there may be circumstances where you object to, or ask us to restrict, our processing of your personal information but we are legally entitled to refuse that request.
In some circumstances, receiving some personal information in a structured, commonly used and machine-readable format and/or requesting that we transmit those information to a third party where this is technically feasible. Please note that this right only applies to personal information which you have provided to us.
Withdrawing your consent, although in certain circumstances it may be lawful for us to continue processing without your consent if we have another legitimate reason (other than consent) for doing so.
Lodging a complaint with the relevant data protection authority, if you think that any of your rights have been infringed by us.
We can, on request, tell you which data protection authority is relevant to the processing of your personal information.

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How to contact us and other important information

If you would like further information on the collection, use, disclosure, transfer or processing of your personal information or the exercise of any of the rights listed above, please contact us at dataprotection@sinocsl.com.