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Privacy Notice pursuant to Article 17 of the Personal Information Protection Law of the People’s Republic of China



RsA Asia (Shanghai) Co Ltd (Company Name) (the “Controller”), informs you, as required by Articles 7, 17, 23, and 30 of the Personal Information Protection Law(“PIPL”), that your personal data will be processing in accordance with the following:




Subject matter of the processing / 处理的主要内容

The Controller will process your personal data, collected from your submission of said personal data, which may include any information that may lead to your identification, this includes but is not limited to your name, your employment history, your contact details, your biometric data, financial information such as bank account details.




Objectives / 目的

Your personal data will be processed only with your express consent (Article 13 of the PIPL), for the following objectives:


您的个人信息只有在您明确同意的情况下才会被处理(《个人信息保护法》第 13 条),目的如下:


Data that will be processed without your express consent (as established in Article 13 of the PIPL) for the following objectives:

To fulfil contractual, pre contractual and tax obligations with you in place,

To fulfil legal obligations determined by law, regulations, or orders from Authority (ex. Anti- money laundering)

To exercise Controller’s rights like the right of defence in front of a court.







Data that will be processed only with your express consent for the following objectives:

To spread/ to communicate your information which your identity could be inferred to third parties.






Processing of Data / 信息的处理

The processing of your personal data it is based on the operations identified in Article 3 and 6 of the PIPL, and more precisely it shall be for a specified and reasonable purpose, and shall be conducted for a purpose directly relevant to the purpose of processing and in a way that has the least impact on personal rights and interests. Collection of personal information shall be limited to the minimum scope necessary for achieving the purpose of processing and shall not be excessive.




Provision of data and consequences of refusal / 提供信息和拒绝的后果

The provision of data related to section 2b is optional. Refusing the processing will not authorise the use of your information abroad.




Recipient of Data / 信息的接受者

The data will be exclusively processing by individuals and processors that are authorised, properly instructed and linked by a contract to the Controller. The processed data are exclusively those that are necessary as established in Article 3 and 6 of the PIPL. Personal data processed by a third party will be also limited by the objectives.




The data may be communicated to Chinese administrative and judicial authorities and private entities to fulfil contractual and legal obligations, and legislative requirements.




You can request an updated list of processors, complete with the identification details of each data processors, from the Controller. The Controller will immediately provide to make it available.


Lawfulness of the processing / 处理的合法性

The lawfulness of the processing is based on Article 13.1 (consent) and Article 13.2 (contractual need) of the PIPL




Data Protection Officer (DPO) / 信息保护负责人

The Data Protection Officer is available at the email address:




Data Subject Rights / 信息主体权利

You can exercise, with regard to your personal data, the rights established by Article 15, 24, 29, 31, 44, 45, 46, 47, and Article 55 of the PIPL (right to access by the data subject, right to rectification, right to erasure, right to restriction of processing, right to data portability, right to object, Right not to be subjected to automated decision making).




Data Retention / 信息保存

The Controller will process your data limited to the minimum scope necessary for achieving the purpose of processing and shall not be excessive. The retention period of personal information shall be the minimum period necessary for achieving the purpose of processing, unless required by law or administrative regulations.


Transfer of data outside of China / 个人信息跨境提供

The management and conservation of personal data is carried out on servers in China and internationally. For information that is processed internationally the Controller will obtain your specific consent, and the Controller will ensure that the transfer of data will follow the actual legal provisions by entering into an agreement, if necessary, which guaranties a level of protection equivalent to the standards established by the PIPL.


Exercise of Rights / 权利的行使

You can exercise your rights by contacting:

您可以通过联系:     来行使您的权利。


The controller of the data is RsA Asia (Shanghai) Co Ltd



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