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Preamble
JCDecaux Advertising (Shanghai) Co.,Ltd. (hereinafter “JCDecaux China” or “we”, “us”, etc.) is very attached to the protection of privacy and personal information. These values form part of JCDecaux China’s corporate social commitments in the context of its Sustainable Development Policy.
JCDecaux China collects or uses your personal information for the purposes of its own business and agrees to implement appropriate measures to ensure the protection, confidentiality and security of the personal information of any individual from whom such information are collected, in accordance with legal requirements.
The purpose of this privacy and personal information protection policy (hereinafter the “Privacy Policy”) is to inform you about the commitments made by JCDecaux China to ensure your personal information are respected and protected.
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.
Definitions
“Personal Information Processor”: the legal entity which determines the purposes of such personal information processing and the means implemented.
“Personal Information”: any kind of information related to an identified or identifiable natural person as electronically or otherwise recorded, excluding information that has been anonymized.
“Processing”: operation or set of operations which is performed on personal information, such as collection, storage, use, processing, transmission, provision, disclosure, and deletion of personal information.
“Entrusted Party”: the legal entity who is entrusted by the personal information processors to process personal information.
Personal information collected
JCDecaux China only collects and processes personal information that is relevant, adequate, not excessive and strictly necessary in relation to the purposes previously determined.
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.
Purposes of Personal information collection
JCDecaux China agrees to collect and process your personal information lawfully and fairly. The processing implemented by JCDecaux China pursues specified, explicit and legitimate purposes. Your data may be processed for the following purposes in particular:
- To manage your use of our services; In this context, the legal ground for the processing is the performance of the contract between you and JCDecaux China.
- To manage the contractual relationship with our clients, service providers and partners (management of the contract, orders, deliveries, invoices, public relations, etc.); In this context, the legal ground for the processing is the performance of the contract between you and JCDecaux China.
- To send you commercial information about us; In this context, JCDecaux China will obtain your consent.
- To analyse your browsing on our websites and improve the use of our websites (see section 8 below on cookies); In this context, the legal ground for the processing is performance of the contract between you and JCDecaux China or obtain your consent (where you agree to use cookies on our websites).
- To handle any questions or requests and deal with any complaints you may have; In this context, the legal ground for the processing is performance of the contract if the request or complaint concerns the contractual relationship between you and JCDecaux China.
- To handle your job application submitted online on one of our websites. In this context, the legal ground for the processing is to sign an employment contract of JCDecaux China.
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.
Personal information retention
JCDecaux China will keep your personal information for as long as necessary to achieve the purposes for which they are collected and processed. JCDecaux China may, however, keep your personal information for a longer period whenever this a legal obligation for us or to take into account the applicable statute of limitation period to assert, exercise or defend legal claims.
In defining an appropriate personal information retention period, JCDecaux China relies in particular on the following criteria:
Personal information on your use of our services are kept for the entire period of the contractual relationship, then in accordance with applicable statute of limitation periods;
Personal information on the management of the commercial relationship with our service providers and partners are kept for the entire period of the contractual relationship, then in accordance with applicable statute of limitation periods;
When you agree to receive marketing communications, JCDecaux China will keep your personal information until you indicate that you no longer wish to receive such communications, or otherwise for the period defined by applicable legislation;
When your personal information are collected in the context of requests/queries relating to IT services and applications, JCDecaux China will keep your personal information for the period necessary to process such requests or queries;
Job application files can be kept up to 3 years from the date of last contact with the applicant, unless the applicant agrees to a longer period; in such case, the personal information can be archived in accordance with the applicable statute of limitation periods.
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.
Security
JCDecaux China will ensure the security of your personal information through a system that uses physical and logical security measures.
The internet environment is not one hundred percent safe; we will try our best to ensure and guarantee the security of the information you send to us. If our physical, technical, or administrative defensive equipment were to be attacked or destroyed, resulting in personal data being accessed by an unauthorized entity, publicly disclosed, altered or destroyed, thereby compromising your legal rights and interests, we will bear the corresponding legal obligations. In the event of an unfortunate personal information incident, we will inform you timely, in accordance with the laws and regulations. At the same time, we will also submit the report regarding handling personal information incidents in accordance with the regulatory authorities’ requests.
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.
Data transfer
JCDecaux China may disclose your personal data to the affiliates, service providers or other third parties outbound of China. We will comply to the requirements described in the applicable personal information protection laws of China.
In such case, JCDecaux China shall require them to take, in accordance with applicable legislation, all organisational and technical measures that permit ensuring an adequate level of protection of your personal information.
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.
Changes to policy
JCDecaux China may update this Privacy Policy at any time to reflect possible new practices and service offers. In such case, the date of the Privacy Policy will be updated and indicate the date when such changes were made. We invite you to check for any possible updates of this Privacy Policy, which will be published on the websites of JCDecaux China. If JCDecaux China makes any changes it considers substantial, you will be informed by a notice posted on our websites.
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.
Contact us
If you would like more information about this Privacy Policy, please contact: tsong.chen@jcdecaux.com.
This Privacy Policy may be updated at any time, so we advise you to check for updates from time to time.
Latest update: November, 2021