Data Protection Policy

Personal Information Protection Policy

This Personal Information Protection Policy (this “Policy”) is applicable to all web services provided by Star Engineering & Consulting (Shanghai) Co., Ltd. (“STAR”) based on the Website.

Updated and effective on 24th July 2020.

This Policy will help you to understand:

I. WHAT PERSONAL INFORMATION WILL WE COLLECT AND HOW WILL WE USE YOUR PERSONAL INFORMATION
II. HOW DO WE SHARE, TRANSMIT AND PUBLICLY DISCLOSE YOUR PERSONAL INFORMATION
III. HOW DO WE PROTECT YOUR PERSONAL INFORMATION
IV. YOUR RIGHTS
V. HOW DO WE PROCESS CHILDREN’S PERSONAL INFORMATION
VI. HOW WILL YOUR PERSONAL INFORM ATION BE TRANSMITTED GLOBALLY
VII. HOW TO UPDATE THIS POLICY
VIII. HOW TO CONTACT US

STAR stresses protection of your personal information and will make every endeavor to protect the security and reliability of your personal information. We are committed to maintain your trust in us and abide by the following principles to protect your personal information: principles of accountability, clear purposes, free consent, minimum necessity, security assurance, subject involvement and transparency. Meanwhile, STAR commits to adopt the security protection measures at the mature standards of the industry to protect your personal information.

Please carefully read this Personal Information Protection Policy before you use the services of the Website. It will be deemed as your acceptance of this Policy once you start to use the services provided by the Website. 


I. What Personal Information Will We Collect and How Will We Use Your Personal Information?

Personal information refers to all electronically or otherwise recorded information which solely or in connection with other information can identify a specific natural person or reflect activities of a specific natural person.

You may use the search function of the Website, which does not require you to create a user account on the Website. Please kindly be noted that when you use the search function of the Website, we will not collect, record or process your key words information and search history.

STAR only collects and uses your personal information for the following purposes:

When you contact us through the phone number or email address we leave on the webpages of the Website, we will save your message/call records and contents or the contact information you provide, i.e. your name, your phone number, your email address and other information you voluntarily provide to us, so that we can get back to you, help you solve your issues, respond to your requests or record the solution and result of the concerned issues or requests.

We are authorized to use the above personal information provided by you during your use of the corresponding service. The storage period of the personal information is limited to the use period of the collected information, unless longer period is required by laws, regulations or procedural purpose. We will cease to use and delete the abovementioned information when you request for deletion of your personal information. The abovementioned information will be stored within the territory of the PRC. The above personal information provided by you may be transmitted to STAR’s affiliates abroad mentioned under II. below based on the purposes stated in this Policy.

We will seek your prior consent in case that we need to use the information for purposes other than those specified in this Policy.

Please be noted that your authorization or consent with respect to our use of your personal information is not required under the following circumstances:

(1) Circumstances related to fulfillment of obligations under laws and regulations by the controller of the personal information;
(2) Circumstances directly related to national security and national defense;
(3) Circumstances directly related to public security, public health and major public interests;
(4) Circumstances directly related to criminal investigation, prosecution, trial and judgment enforcement;
(5) Circumstances requiring maintaining major legitimate rights and interests with respect to life and property of the personal information subject or other individuals but are difficult to obtain the consent of the owner of the personal information;
(6) Circumstances that the personal information involved is publicized by the personal information subject on his/her own;
(7) Circumstances necessary for execution and performance of the contract requested by the personal information subject;
(8) Circumstances that the personal information is collected from the legally and publicly disclosed information, e.g., legal news report, government information disclosure, etc.;
(9) Circumstances that are necessary to maintain safe and stable operation of the offered products and/or services, e.g., products and/or services troubleshooting;
(10) Circumstances necessary for the personal information controller as a news agency to conduct legal news report;
(11) Circumstances necessary for the personal information controller as an academic institution to conduct statistics analysis or academic research out of public interests and the personal information included in the academic research results will be de-identified when externally shared;
(12) Other circumstances specified by laws and regulations. 


II. HOW DO WE SHARE, TRANSMIT AND PUBLICLY DISCLOSE YOUR PERSONAL INFORMATION

1. Sharing

We will not share your personal information with any company, organization or individual outside STAR except:

(1) Sharing with your explicit consent: We will share your personal information with other parties after obtaining your explicit consent.
(2) We may externally share your personal information in accordance with laws and regulations or mandatory requirements of the competent government authorities.
(3) Sharing with our affiliates: Your personal information may be shared with our affiliates. We will only share necessary personal information to the extent of the purposes stated in this Policy. The affiliate will re-seek your authorization and consent in case that it needs to change the purpose to process your personal information.

Our affiliates include any company and organization and the legal successor of such company or organization that STAR controls or will control or is or will be controlled by or under common control with STAR. “Control” refers to directly or indirectly holding the power to affect the management of the referring company, no matter through ownership, voting securities, contract or other means recognized by the people’s court.

We will enter into appropriate confidentiality agreements with the companies, organizations and individuals with whom we share your personal information requiring personal information processing in accordance with our instructions, this Policy and any other relevant confidentiality and security measures.

2. Transmission

We will not transmit your personal information to any company, organization or individual, except:

(1) Transmission with explicit consent: After obtaining your expressed consent, we will transmit your personal information to other parties;
(2) In case of merger, acquisition or liquidation due to bankruptcy, if any personal information transmission is involved, we will require the company or organization to possess your personal information continue to be bound by this Policy, otherwise we will require such company or organization to re-seek your authorization and consent.

3. Public Disclosure

We will only publicly disclose your personal information under the following circumstances:

(1) After obtaining your explicit consent;
(2) Disclosure under laws: We may publicly disclose your personal information subject to laws, legal procedures, litigation or mandatory requirements of the competent government authority.


III. HOW DO WE PROTECT YOUR PERSONAL INFORMATION

We have adopted the security protection measures in line with industry standards to protect the personal information provided by you from unauthorized access, public disclosure, use, modification, damage or missing. We will take all reasonable and feasible measures to protect your personal information, e.g.:

(1) We provide https for safe browsing of the Website;
(2) We will use encryption to secure data confidentiality;
(3) We will use trusted protection system to avoid malicious data attack;
(4) We will deploy visit control system to ensure only authorized personnel have access to the personal information; and
(5) We will hold security and privacy protection training to strengthen employees’ awareness of importance on personal information protection.

Internet cannot be 100% safe, although the abovementioned reasonable and effective measures have been taken and the standards required by the applicable laws have been abided by, the Website still cannot guarantee the security of your personal information during communication through unsecure channel. Therefore, the users shall take active measures to ensure the security of the personal information, e.g.: change password on a regular basis, use complex password, not share your personal information including the password with others, assist us to ensure your account security. In case that our physical, technical or managerial protection facilities are damaged, causing your legitimate rights and interests damaged due to unauthorized access, public disclosure, alteration or destruction of the information, we will assume liabilities subject to laws.

Upon occurrence of any unfortunate personal information security incident, we will timely in accordance with requirements provided in laws and regulations inform you of: basic security incident information and possible impact, countermeasures we have adopted or will adopt, suggestions on preventing and mitigating risks, remedial measures for you, etc. We timely notify you of the incident via email; in case that it is impossible for us to inform each subject of the personal information, we will use reasonable effective ways to publish announcement. Meanwhile, we will also actively report the aftermath of such incident in accordance with the requirements of the regulatory authorities.


IV. YOUR RIGHTS

You have the following rights in relation to us regarding your personal information as far as the respective legal requirements are met:

(1) Right of access;
(2) Right to correction;
(3) Right to deletion;
(4) Right to restriction of personal information processing;
(5) Right to objection against the process as well as the right to personal information transfer.

If you wish to exercise the rights mentioned above, here you can contact us by e-mail at data.protection@star-cooperation.cn.

In case of any of the following circumstances with respect to your information, we may be unable to respond to your request in accordance with laws and regulations:

(1) Circumstances related to fulfillment of obligations under laws and regulations by the controller of the personal information;
(2) Circumstances directly related to national security and national defense;
(3) Circumstances directly related to public security, public health and major public interests;
(4) Circumstances directly related to criminal investigation, prosecution, trial and judgment enforcement;
(5) Circumstances that can be proven by the personal information controller with sufficient evidence that the subject of the personal information has subjective malic or has misused his/her rights;
(6) Circumstances that are difficult to obtain the consent of the owner of the personal information but rejection of the request is necessary given major legitimate rights and interests with respect to life and property of the owner of the personal information or other individuals;
(7) Circumstances that responding to your request will cause the legitimate rights and interests of you, other individuals or organizations be severely impaired;
(8) Circumstances involving trade secretes; and
(9) Other circumstances provided by laws and regulations.


V. HOW DO WE PROCESS CHILDREN’S PERSONAL INFORMATION

Our products, website and services are mainly adult oriented. If you are a child under the age of 14, you should obtain the written consent of your parent or custodian before using our services on the Website. We will protect children’s personal information in accordance with relevant national laws and regulations.

With respect to the children’s personal information collected with consent of the parents, we will only publicly disclose such information as permitted by laws, explicitly consented by the parents or custodians or under the circumstances necessary for protection of such children.

Despite of different definitions of a child under local laws and customs, we treat anyone under 14 years old as a child.

If we find that we have collected children’s personal information without prior proven consent of the parents or custodians, we will try to delete the relevant data as soon as possible.


VI. HOW WILL YOUR PERSONAL INFORMATION BE TRANSMITTED GLOBALLY

In principle, the personal information we collected will be stored within the territory of the PRC. STAR commits to provide adequate protections measures as required by the laws and regulations of the People’s Republic of China to protect your personal information. In case of the need to transmit your personal information to other countries/regions, we will otherwise seek your authorization and consent and will secure adequate protection of your personal information in accordance with this Policy under such circumstances.

As we provide products or services through worldwide resources and servers, we may need to transmit your personal information to STAR’s affiliates mentioned under II. above for the purpose stated in this Policy. Thus, we may transmit your personal information to other countries/regions with laws and data protection compliance requirements that may differ from those of China, or your personal information may be visited by such countries/regions. These jurisdictions may provide different data protection laws or may not provide any relevant laws. Under such circumstances, we will ensure your personal information will receive adequately same protection as within the People’s Republic of China.


VII. HOW TO UPDATE THIS POLICY

This Policy may be amended.

We will not reduce the rights you are entitled to in accordance with this Policy without your explicit consent; we will publish any amendment made to this Policy on this webpage.

Upon update of this Policy, we will publish the updated version on this webpage and remind you of the update via website announcement or other appropriate approach such as pop-up notice before it takes effect.

In case of any major amendment, we will also provide more obvious notice (we will notify specific amendments to this Policy via including but not limited to special notice on the webpage.).

The major amendments to this Policy include without limitation:

(1) Major changes in our service model, e.g., purpose to process personal information, type of the personal information processed, way to use personal information, etc.;
(2) Major changes in our ownership structure, organization structure, etc., e.g., all changes caused by business adjustment, bankruptcy, M&A, etc.;
(3) Changes in the main target to share, transmit or publicly disclose the personal information;
(4) Major changes in your rights with respect to personal information processing and way to exercise such rights;
(5) Changes in our accountable department, contact information and complain channel with respect to per-sonal information security;
(6) In case that the assessment report of personal information security impact indicates high risks.

We will archive the old versions of this Policy for your reference.


VIII. HOW TO CONTACT US

If you have any questions, opinions or suggestions about this Policy, please contact us via the following contact information:

Company: Star Engineering & Consulting (Shanghai) Co., Ltd.
Address: Room 6H and 6I, 6th Floor, No. 567 Weihai Road, Jing’an District, Shanghai, PRC
Contact details data protection officer: data.protection@star-cooperation.cn

Generally, we will reply within thirty days.

Please amicably consult with STAR in case that you are in any dispute with us due to this Policy. You also have the right to contact the personal information protection supervisory authority in the event that settlement can-not be reached through such consultation.

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