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1.1. PERSOLKELLY Shanghai (China) Co., Ltd., PERSOLKELLY China Co., Ltd., PERSOLKELLY Shenzhen Co., Ltd., PERSOLKELLY Consulting (Shanghai) Co., Ltd., and PERSOLKELLY Consulting (Shenzhen) Co., Ltd. (collectively, the “Company”) respects your privacy and we acknowledge that you have certain rights related to any personal information we collect from you and we have certain obligations in respect of the same. The Company supports various international and local privacy laws, and has procedures in place to meet the requirements of those laws.

1.2. This privacy policy (“Privacy Policy”) discloses and states our privacy principles and/or our practices for collecting, acquiring, storing, using and/or disclosing your personal information, so that you may know and understand how we may collect, use, disclose, process and share your personal information.

1.3. For the avoidance of doubt, “personal information” means any information (excluding anonymized information) recorded electronically or otherwise concerning any identified or identifiable natural person.  References to “us” or “we” shall refer to the Company.


2.1. In order for us to provide our services and operate our business, provide services of recruiting and placing individuals for potential labor dispatch (and related services) to our customers and/or directly at the Company, acting as the employer or hirer of record for individuals employed or engaged by the Company, or provide human resources related services to our customers, we must collect certain personal information from and about individuals who are candidates, employees, contractors, former employees, website users and visitors.

2.2. The types of personal data collected, used, processed, disclosed and stored by us depends on the circumstances and/or the purposes for which we may need to process your personal data. Hence, subject to the aforesaid, such personal data may include :
• Name;
• Contact information (address, phone number, e-mail address);
• Employee identification number;
• Date of birth;
• Contents of any other identification provided to the Company for application or employment purposes;
• Education and employment history;
• Work-related skills and experience;
• Professional credentials or licenses;
• Membership in professional organizations;
• Any other information contained on an individual’s Curriculum Vitae (CV);
• Results of background checks;
• Citizenship and work authorization status;
• Disability and health-related information;
• Information submitted by you or obtained by us relating to your absence from work due to leave of absence, sickness or otherwise;
• Next-of-kin or emergency contact information;
• Information from and related to publicly published profiles you’ve created on job-related
social media platforms and job boards (such as LinkedIn, Monster, or Indeed);
• Information provided by references;
• Information regarding your career interests, preferences, and qualifications;

2.3. In addition, you acknowledge and agree that, under certain circumstances and consistent with prevailing laws, we may request types of personal data that are viewed by some countries as “sensitive”:
• National identification, tax identification, passport number and/or social security number(s);
• Mobile phone number;
• Religious belief;
• Financial or bank account information;
• Results of drug, criminal, and/or background screenings;
• Benefits selections, potentially including health insurance and retirement planning information;
• Biometric data;
• Information contained within your personnel file with the Company, such as performance reviews, disciplinary action, and other payroll related information; and
• Health information, including that related to a work-related claim (e.g. workers’ compensation claim).

2.4. In some jurisdictions, in order to comply with statutes, rules, and regulations pertaining to equal employment opportunities or to assist the Company or its related corporations in compiling data for its equal opportunities practices and reporting, we may also ask you to provide gender, race/ethnicity or disability information. The provision of this type of information will be voluntary, unless it is required by law, and failure to provide this information will not hinder your employment or project opportunities.

2.5. Your interactions with our websites may also result in the collection, processing, and storage of the following types of information from you:
• Geolocation data;
• Other information you may provide to us, such as through surveys, interactions with our social media, or other media used to contact the Company.
You may change or turn off this on-going collection, processing, and storage function as described in the Internet browser support file or by disabling the function to accept and store cookies in your Internet browser settings.

2.6. Some of our websites require you to provide your personal information, such as when you create a profile and log-in credentials. Instead of having to type in your personal information, some of these functionalities may allow you to use third-party authentication tools such as Facebook, Twitter, and Google to populate certain fields. By authenticating through one of the social media options, you allow us to receive your personal information and other information that is accessible through these tools. This information may be incorporated into your profile for the purposes set out in this Privacy Policy. For any such tool you choose to use, we encourage you to also review the tool provider’s privacy policy and any terms and conditions.

2.7. We may use your personal information to permit you to participate in live social media feeds. If you choose to participate, your public username may be displayed on the sites along with your post, including, but not limited to, comments, images, and video.

2.8. We may provide you with access to third-party functionality that allows you to post content to your social media account(s). Any information that you provide to your social media account(s) through use of such third-party functionality is governed by the applicable third party's privacy policy, and not by this Privacy Policy. For the avoidance of doubt, we are not responsible for any personal data that you provide to such third party.

2.9 With respect to certain personal information you provided about other individuals (e.g., your close relatives, family members, and emergency contacts), it is your responsibility to make such individuals aware before you provide their personal information to the Company and to obtain their necessary consent.

2.10. We do not intend to directly collect, use or disclose information that may be considered sensitive about minors under the age of sixteen (16) and persons without civil capacity or with limited civil capacity. If we collect such information, it is purely accidental and not deliberate. We will comply with relevant laws and further obtain the consent of their legal guardian or delete such information upon the written request of their legal guardian.


3.1. We will/may collect, use, disclose and/or process your personal information for one or more of the following purposes :
(a) administering, processing and/or dealing with any interactions between you and the Company and/or any of its related corporations including but not limited to any application by you for employment or work with the Company;
(b) recruiting, assessing and/or matching you with/for potential positions or assignments with third party organizations (or our customers), and/or dealing with matters related thereto such as offering you a placement of work or job with such third party organizations (or our customers) or referring you for employment to a third party organization (or our customer);
(c) administering, managing and/or dealing with the provision of work or job placement services to you. This includes us sharing your personal information with our customers or third party organizations, for your potential placement or employment opportunities with those customers/third party organizations who are seeking employees or workers, or with the organization to which you have been assigned to work;
(d) administering or terminating your employment and/or working relationship with us or with third party organizations (or our customers), including onboarding and training, employee benefits and remuneration management, performance review, personal or career development or disciplinary action matters;
(e) carrying out your instructions or responding to any enquiry given by (or purported to be given by) you or on your behalf;
(f) administering, facilitating, processing and/or dealing in any matters relating to your use of any of the Company’s or its related corporations’ websites, any functionalities on the websites or any interactions or activities carried out by you on or through any of the Company’s or its related corporations’ websites, such as but not limited to live social media feeds;
(g) monitoring, processing and/or tracking your use of any of the Company’s or its related corporations’ websites in order to provide you with a seamless experience, facilitating or administering your use of any of the Company’s or its related corporations’ websites, and/or to assist us in improving your experience in using any of the Company’s or its related corporations’ websites;
(h) contacting you or communicating with you via phone/voice call, text message and/or fax message, email and/or postal mail for the purposes of administering your use of any of the Company’s or its related corporations’ website or any interactions you have with us, or for the provision of our services to you. You acknowledge and agree that such communication by us could be by way of the mailing of correspondence, documents or notices to you, which could involve disclosure of certain personal information about you to bring about delivery of the same as well as on the external cover of envelopes/mail packages;
(i) maintaining and preserving personal information and employment records of employees to comply with any laws and regulations or any document keeping or audit requirements;
(j) dealing with entry and exit matters and/or work permit matters;
(k) carrying out due diligence or other screening activities (including background checks) in accordance with legal or regulatory obligations applicable to us, the requirements or guidelines of governmental authorities which we determine are applicable to us, and/or our risk management procedures that may be required by law or that may have been put in place by us;
(l) preventing or investigating any fraud, unlawful activity or omission or misconduct, whether or not there is any suspicion of the aforementioned; dealing with conflict of interests; or dealing with and/or investigating complaints;
(m) creating reports with respect to our interactions with you, and/or producing statistics and research of such interactions for internal and/or statutory reporting and/or record-keeping requirements for us or our related corporation(s);
(n) complying with or as required by any applicable law, governmental or regulatory requirements of any jurisdiction applicable to us or our related corporations, including meeting the requirements to make disclosure under the requirements of any law binding on us or our related corporations, and/or for the purposes of any guidelines issued by regulatory or other authorities with which we or our related corporations are expected to comply;
(o) complying with or as required by any request or direction of any governmental authority which we are expected to comply with; or responding to requests for information from public agencies, governmental authorities, statutory boards or other similar authorities. For the avoidance of doubt, this means that we may/will disclose your personal information to the aforementioned parties upon their request or direction;
(p) storing, hosting, backing up (whether for disaster recovery or otherwise) your personal information, whether within or outside China;
(q) facilitating, dealing with and/or administering external audit(s) or internal audit(s) of the business of the Company and/or its related corporations;
(r) responding to litigation proceedings, seeking legal rights and remedies, replying in arbitration or litigation proceedings, and administering any complaints or claims;
(s) carrying out and/or facilitating a business asset transaction or a potential business asset transaction, where such transaction involves the Company and/or its affiliates as a participant, and there may be other third party organizations who are participants in such transaction. The term “business asset transaction” means the purchase, sale, lease, merger or amalgamation or any other acquisition, disposal or financing of an organization or a portion of an organization or of any of the business or assets of an organization,;
(the purposes set out above shall be collectively referred to as the “Purposes”).

3.2. The Company may/will need to disclose or transfer your personal information to third parties, whether located within or outside China, for one or more of the above Purposes, as such third parties would be processing your personal information for one or more of the above Purposes. In this regard, you hereby acknowledge, agree and consent that we may/are permitted to disclose or transfer your personal information to such third parties (whether located within or outside China) for one or more of the above Purposes and for the said third parties to subsequently collect, use, disclose and/or process your personal information for one or more of the above Purposes. Without limiting the generality of the foregoing or of the immediately preceding paragraph setting out the Purposes, such third parties include:
(a) our associated or affiliated organizations or related corporations;
(b) any of our agents, contractors or third party service providers that process or will be processing your personal information on our behalf including but not limited to those which provide administrative or other services to us such as mailing houses, telecommunication companies, information technology companies, data centers, IT service providers, insurance companies and bank staff, etc.;
(c) our customers or third party organizations, who may be your potential employers or hirers or organizations which engage you for your services, etc.;
(d) third parties to whom disclosure by the Company of your personal information is for one or more of the Purposes and such third parties would in turn be collecting and processing your personal information for one or more of the Purposes; (e) public agencies, governmental authorities, statutory boards and/or industry associations; and;
(f) any potential asset acquirer of all or any part of the business of the Company, or any acquirer or equity subscriber in any merger or acquisition of the Company.

3.3. Your consent pursuant to this Privacy Policy is additional to and does not supersede any other consents that you had provided to the Company with regard to processing of your personal information.

3.4. Data that has been anonymized does not personally identify you and is not covered by this Privacy Policy.

3.5. We hold our employees, agents, and suppliers accountable for maintaining the trust that you place in us with your personal information. Your personal information will not be used or shared except as in accordance with applicable law relating to personal information.

3.6. For the purpose of our business operations, we may appoint third party service providers to provide certain services or realize certain functions as may be directed by us. We will require the companies, organizations and individuals we appoint to process your personal information only to the extent as authorized by us, and not to use such information for any other purpose beyond the scope of authorization.

3.7. You acknowledge, agree and authorize that your personal information may be shared with third parties as set out in paragraph 3.2 above. If you would like to receive a list of recipients or more information regarding our sharing of your personal information, you may contact us in the manner set out in Section 8 below.

3.8. In accordance with paragraph 3.2 above, if we become subject to an acquisition or merger, we will require the party receiving your personal information to continue to comply with this Privacy Policy. Prior to any transfer of your personal information, we will send you an appropriate notice to advise the recipient’s company or individual name and contact details. If the recipient changes the Purpose or method of processing, we will require it to obtain your separate consent again.

3.9. Consistent with paragraph 3.2 above, as a result of the scope of the Company’s operations, the sharing of your personal information with our other group entities, service providers, and customers may result in your personal information being sent to countries outside of your country of residence, which may have data protection laws that differ from those in your country of residence. Regardless of the source or destination location of your information, we will at all times protect your personal information as described in this Privacy Policy, and in accordance with applicable data protection laws when transferring your personal information. We will require the recipient to protect your personal information in accordance with the relevant personal information protection laws and regulations of the country where it is located, and to ensure that your personal information is accorded at least the same degree of protection outside China as it is accorded under the applicable laws within China. If you would like to receive more information regarding these cross-border transfers and protections, you may contact us in the manner set out in Section 8 below.


4.1. The Company’s websites use "cookies" to help personalize the online experience. A cookie is a piece of data stored on the user’s computer or mobile device tied to information about that user. They also allow us to identify those devices when they return to a website. You can set your browser to notify you before you receive a cookie, giving you the option of whether to accept it. You can also set your browser to turn off cookies. If you do so, some areas of our websites may not function properly. We use both session ID and persistent cookies. A session ID cookie simply expires once the user closes the browser. A persistent cookie is a small text file stored on the user’s hard drive for an extended period of time. These can be removed by following the instructions in your Internet browser’s help file.

4.2. To help us provide better service, we sometimes collect anonymous information from visits to our websites through the use of "web beacons." These do not access your personal data, but rather allow us to log users who have visited our websites. This anonymous information is sometimes known as "clickstream data." We or our vendors may use this data to analyze trends and statistics to help us provide better customer service. If you do not want your transaction details used in this manner, see the paragraph above on cookies.

4.3. Links: For links to organizations not affiliated to us, We are not responsible for the privacy practices or the content of such websites. We recommend you review the terms and conditions of use and privacy policies in place on such websites.


5.1. The amount of personal information you are required to supply when requesting our services will be limited to that which is relevant to and reasonable for the supply of such services or for the purposes for which such personal information is being collected.

5.2. Where you have asked us to do the following, or have otherwise given us your consent to do the following, we may periodically use your contact information to send you updates via e-mail in order to alert you to promotional opportunities or services relevant to your interactions with us, such as jobs in our database that match your selected criteria. Each notification will provide instructions on how to opt out of receiving similar e-mails from the registered service or resource. At the point where we request personal data about you, our site also gives you the opportunity to decide which communications you wish to receive. The database is automatically updated with your preferences when you opt out. When your interactions with the Company have resulted in your registration for multiple services or resources it may be necessary to opt out from each service separately.

5.3. Additionally, you have the right to request access to, to withdraw your consent to the use and processing of, to request the correction of inaccuracies of, and to request the deletion of, personal information that the Company maintains about you, or that is in the Company’s possession or under its control. Notwithstanding the foregoing, you understand that we reserve the right to refuse all or any part of your request by providing you with the reasons for our refusal within a reasonable time (e.g., when we can demonstrate that we have a legitimate need to process your personal information or where there is sufficient evidence to show that you are acting in bad faith or abusing your rights) where it is impossible or practically difficult for us to comply with your request. We may limit or deny requests for access or charge reasonable fees for access, in accordance with applicable law or requirements of governmental authorities.

5.4. Where you seek access to and/or seek to correct the personal information currently in our possession or control, we will need enough information from you in order to ascertain your identity as well as the nature of your request, so as to be able to deal with your request.

5.5. We will process your request to withdraw your consent within a reasonable time from such a request being made, and will thereafter not collect, use and/or disclose your personal information in the manner stated in your request. However, your withdrawal of consent could result in certain legal consequences arising from such withdrawal. In this regard, depending on the extent of your withdrawal of consent for us to process your personal information, it may mean that we will not be able to continue providing our services such as recruitment, placement, or employment, as the case may be.


6.1. We will take reasonable efforts to ensure that your personal data is accurate and complete, if your personal data is likely to be used by the Company to make a decision that affects you, or disclosed to another organisation. However, this means that you must also update us of any changes in your personal data that you had initially provided us with. We will not be responsible for relying on inaccurate or incomplete personal data arising from you not updating us of any changes in your personal data that you had initially provided us with.

6.2. We will also put in place reasonable and appropriate administrative, physical and technical measures such as up-to-date antivirus protection, encryption, use of privacy filters, access control, password protection and disclosing personal data both internally and to our authorised third-party service providers and agents only on a need-to-know basis to prevent any unauthorized access, collection, use, disclosure, copying, modification, disposal, leakage, loss, damage and/or alteration of your personal data. However, we cannot assume responsibility for any unauthorized use of your personal data by third parties which are wholly attributable to factors beyond our control.

6.3. You should be aware, however, that no method of transmission over the Internet or method of electronic storage is completely secure. While security cannot be guaranteed, we strive to protect the security of your information and are constantly reviewing and enhancing our information security measures

6.4. We will also put in place measures such that your personal data in our possession or under our control is destroyed and/or anonymized as soon as it is reasonable to assume that (i) the purpose for which that personal data was collected is no longer being served by the retention of such personal data; and (ii) retention is no longer necessary for any other legal or business purposes.


7.1. In the event a breach of security leading to accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, personal data, we shall promptly assess the impact and once assessed that it is a notifiable data breach, we shall report this breach to the relevant authority(ies) based on the Country data breach notification requirements. We will notify you when the data breach is likely to result in significant harm to you after our notification to the relevant authority(ies). We may also notify other relevant regulatory agencies, where required

7.2. If we are a Data Intermediary, we shall inform the Data Controller (our clients) immediately of any data breach so they can promptly assess the impact and comply with their data breach notification obligation.


We may update this Privacy Policy from time to time. If we change our Privacy Policy, we will post the revised version here, with an updated revision date.


If you have any questions, grievances or complaints, or comments about this Privacy Policy and/or the handling of your personal information by us, please contact us at :
Address: Unit 1201,
               Two ICC, No.999, Huaihai Road (M),
               Shanghai 200031 P.R.China
Email:     Leo_jiang@persolkelly.com