Privacy and Personal Information Protection Policy

Scope

This Privacy Policy applies to all processing of personal information implemented by JCDecaux China, acting as the personal information processor, within China, in relation to external persons (hereinafter “you”), including but not limited to clients, prospects, partners, job applicants, users of our products and services , suppliers, service providers and Internet users.

Personal information collected

JCDecaux China takes all useful measures to ensure that your information are accurate, complete and, where necessary, kept up to date.

JCDecaux China agrees to obtain the consent of the individuals whenever consent is required and to inform them of the processing of their personal information.

We process personal information concerning you and which you have provided to us in the following contexts in particular:

• When you use our services;
• When you browse our websites;
• When you provide us with products or services;
• When you take part in events or public relations activities organised by JCDecaux China;
• When you give your consent to receive our newsletters and other commercial information from us;
• When you wish to apply for a job offer at JCDecaux China;
• When you wish to get in touch with us to ask us a question or make a complaint.

In these contexts, JCDecaux China may collect and process the following personal information:

• Your identity: surname, name, preferred form of address (Mr./Mrs./Ms.), date of birth, photocopy of your identity card whenever necessary, and your function;
• Your contact details: postal address, email, phone number;
• Your job application information: CV, motivation letter, interview notes;
• Your technical and browsing information on our websites (please see section 8 below on cookies);

Any other information you directly and voluntarily provide to us in the course of your use of our websites, services and any contracts you may enter into with us.
The mandatory nature of any information to be completed by you is typically marked in the corresponding forms at the time such information is collected. Choosing not to share this information may affect your normal use of our Services. Any failure to complete that information or any response JCDecaux China considers abnormal may result in JCDecaux China refusing to process your request.

JCDecaux China may ask you to provide certain personal information for direct marketing/ communication purposes. You may give your free and explicit consent or not for the collection and processing of your personal information.

You agree that the personal information you provide about yourself to JCDecaux China will be current, accurate, complete and unequivocal.

We will use the personal information we collect from you only for the purposes described in this Privacy Policy or for purposes that we explain to you at the time we collect your personal information. However, we may also use your personal information for other purposes that are not incompatible with the purposes we have disclosed to you if and where this is permitted by applicable personal information protection laws.

Personal information recipients

JCDecaux China can provide access to your personal information to the companies of its group, to local government authorities or bodies, to its partners and to its possible third-party service providers, acting as Entrusted Parties, for the provision of services in connection with JCDecaux China’s services and IT applications (such as hosting, storage, analytical, processing, database management or IT maintenance services). 

These third-party providers will act only on the instructions of JCDecaux China and will only have access to your personal information to achieve the purposes pursued upon collection of such personal information and shall be under the same security and confidentiality obligations as JCDecaux China.

JCDecaux China agrees to inform you and obtain your prior consent, before disclosing your personal information to partners for direct marketing purposes.

In addition, your personal information may be disclosed on the following grounds:
In the context of a merger or acquisition of all or part of JCDecaux China by a third party, as is hereby accepted by you;
In response to legal or administrative proceedings of any kind or enforcement measures requested by the competent authorities;
To comply with legal obligations, protect the rights and/or safety of an individual, protect the rights and property of JCDecaux China, including the need to ensure that this Privacy Policy is respected and to prevent any technical, security or fraud-related issues.

Cookies

You are informed that, when browsing our websites, cookies can be placed on your web browser to enable you, in particular, to benefit from optimal browsing. Cookies are information stored on the terminal equipment of an Internet user. Our websites use cookies to send information to the user’s browser, enabling the browser to pass information back to the original website (for instance, a session ID, language preference or a date). Other types of trackers, such as Web beacons, can also be used. These beacons make calls to servers to display a pixel and enable us to share information with third parties for the purposes described in our Cookie Management Policy.

Privacy protection for Children

Generally, JCDecaux China is not intended for child under the age of 14, and we have no intention of collecting personal information from the said children. If a parent or guardian learns that a child has provided us with personal information, that child’s parent or guardian should contact us and send a request marked "Privacy – Urgent" if they would like the information submitted by the child deleted from our database. We will use all reasonable efforts to delete such information from our database.

Your personal information protection rights

Under applicable personal information protection laws, you have certain rights regarding the collection and processing of your personal information, namely:

• A right to be informed: you have the right to be informed in a concise, transparent, intelligible and easily accessible form about the way in which your personal information are processed.
• A right of access: you have the right to obtain (i) confirmation as to whether personal information concerning you are processed or not and, if processed, to obtain (ii) access to such personal information and a copy thereof.
• A right to rectification: you have the right to obtain the rectification of any inaccurate personal information concerning you. You also have the right to have incomplete personal information completed, including by means of providing a supplementary statement.
• A right to erasure: in some cases, you have the right to obtain the erasure of personal information concerning you. However, this is not an absolute right and JCDecaux China may have legal or legitimate grounds for keeping such personal information.
• A right to restriction of processing: in some cases, you have the right to obtain restriction of the processing of your personal information.
• A right to object to processing: you have the right to object JCDecaux China to process your publicly disclosed information, or object JCDecaux China to process your personal information via automatic decision making means. When your personal information are processed for direct marketing purposes, you have the right to object at any time to the processing of such personal information. You may, in particular, exercise this right by clicking on the “unsubscribe” link provided at the bottom of any messages received.
• A right to lodge a complaint with the competent supervisory authority: you have the right to contact a supervisory authority (in China, the CAC) to complain about JCDecaux China’s personal information protection practices.

To exercise these rights, you can send a request to the following address: JCDecaux China， 200336, F21, V-capital Mansion, No.333 Xianxia Rd., Changning District, Shanghai or an email to tsong.chen@jcdecaux.com, together with your identity document number to verify you are the data subject.

Links to third-party websites

While browsing our websites, you may come across content containing links to third-party applications and websites. JCDecaux China has no control over the cookies or other functions used by such third-party applications and websites, and any personal information processing that may be implemented by such applications and websites are not governed by this Privacy Policy.

Accordingly, it is up to you to directly contact and/or visit such third-party applications and websites to obtain further information on their personal information protection guidelines.