Introduction

Latest update and entry into force of this policy: July 11, 2023

FESCO Adecco Human Resources Service Shanghai Co., Ltd. (“FESCO Adecco”) attaches significant importance to the information security and privacy protection of users. FESCO Adecco strictly complies with laws and regulations and the following privacy protection principles to provide you with more secure and reliable services: 

1. Security and reliability: We will do our best to prevent leakage, destruction or loss of your personal information through reasonable and effective information security technology and management process. 
2. Autonomous choice: We provide you with convenient information management options so that you can make suitable choices to manage your personal information. 
3. Protection of secrecy of correspondence: We strictly abide by laws and regulations, protect your secrecy of correspondence, and provide you with secure communication services. 
4. Reasonably necessary: We only collect necessary information for us to provide services.
5. Clarity and transparency: We strive to present our privacy policy to you in simple and straightforward language so that you can have a clear understanding of how we process your personal information. 
6. Integration of privacy protection into service design: We integrate various factors including law, service and design, and incorporate the concept of privacy protection at every stage of service development. 

This Privacy Policy explains to you:

1. Information we collect; 
2. How we use the information collected;
3. How you manage your own information;
4. Information we share;
5. Service-related announcements;
6. Cookies and similar technology services;
7. Place and period of storage of information;
8. Information security;
9. Protection of minors;
10. Scope of application;
11. Contact us; and
12. Update.

Before you use our service, it is important that you carefully read and fully understand the Privacy Policy (this “Policy”) and confirm your full understanding and consent before using our service. If you have any query, please contact us. 

1.Information we collect

We only collect personal information necessary for the performance of our business functions in accordance with the principles of legality, legitimacy, necessity and integrity and the principle of purpose limitation.
Personal information means information relating to an identified or identifiable natural person, whether recorded electronically or otherwise, including the name, date of birth, identification number, biometric information, address, telephone number, email address, health information, tracking information, etc., of a natural person. Personal information does not include anonymized information.
Sensitive personal information means personal information which, if leaked or illegally used, is likely to result in an infringement upon personal dignity or endanger personal or property security of a natural person, including biometric data, religious belief, specific identity, health information, financial accounts, location tracking, etc., and personal information of minors under the age of 14.
1.1 Personal information you voluntarily provide when using our service 
1.1.1 Personal information that you insert and upload when using our service
If you use the "Contact Us" service, your personal information includes the name, phone number, email address, company name, position, etc. you provided;
Some of our services may require you to provide specific personal information (including sensitive personal information) so that certain functions can be performed. If you choose not to provide such information, it will be likely that we are unable to provide specific business functions while your use of other business functions in the services will not be affected. By providing your personal information (including sensitive personal information) voluntarily, you agree that we will process your personal information (including sensitive personal information) for the purposes and in the manner set out in this Policy.

1.2 Information we collect when you use our service
1.2.1 Log information. When you use our services, we may automatically collect the relevant information and store it as service log information. 
(1) Device information. For example, device model, operating system version, unique device identifier, battery, signal intensity, etc.
(2) Software information. For example, the version number of the software and the type of browser. To ensure the security of the operating environment or to provide services, we may collect information on the mobile applications and other software you use. 
(3) IP address.
(4) Service log information. For example, information you search and view when using our service, service failure information and referral web site information.
(5) Communication log information. For example, the account by which you communicate when using our services, communication time and duration.
1.2.2 Location information. When you use the location-related service, we may record the location information of your device to provide you with the relevant service.
(1) We may collect your geolocation by means of IP address, GPS, WiFi or base station when you use our service; and
(2) Information provided by you or other users when using our service may include your geolocation.

2.How we use the information collected

We will use the information collected for the following purposes in strict compliance with the provisions of laws and regulations and the agreements with users. If we use your personal information for other purposes not specified in this Policy or use information collected for a particular purpose for other purposes, we will obtain your consent again.
2.1 Personal information collected in the "Contact Us" service: contacting you, recommending information that you may be interested in, etc.
2.2 To meet your personalized needs.For example, language setting, location setting, personalized help services. 
2.3 To develop and optimize services. For example, if our systems fail, we will record and analyze the information generated during the system failure to optimize our services. 
2.4 To invite you to participate in surveys on our services.  In order to provide you with better experience, improve our services or for other purposes you agree, we may use the information collected in certain services for other services provided by us, subject to the relevant laws and regulations. For example, we may use the information collected from your use of one of our services to present you with personalized contents or advertisement in other services, or to use such information in user research analysis and statistics, etc. In order to ensure the security of the services and to help us better understand operating conditions of our applications, we may record relevant information, such as how often you use the applications, failure information, overall usage, performance data and source of the application. We will not match the information we store in the analysis software with the personally identifiable information you provided in the application.

3.How you manage your own information

3.1 You may access, modify and delete the registration and other personal information provided by you in the course of using our services, or you may contact us in accordance with the notification guidelines.
3.2 We will collect and use your information only for the purpose of implementing the functions of our services as set out in this Policy. If you find that the way we collect or use your personal information is in violation of laws, administrative regulations or our agreement, or other circumstances provided in laws or administrative regulations, you may request us to delete your personal information. You may also request us to correct any error in your personal information collected and stored by us. Please contact us via the contact details set out in this Policy. 
3.3 If you access, modify and delete the relevant information, we may require you to verify your identity to ensure account security. 
3.4 You may withdraw your consent by contacting us through the contact details set out in this Policy. If you withdraw your consent, we may not be able to continue providing you with the services for which your consent is withdrawn, and we may no longer process your corresponding personal information.
3.5 Please understand that due to technical restrictions and legal or regulatory requirements, we may not be able to meet all your requirements and we will respond to your request within a reasonable period of time.

4.The information we share

We set strict limits on the sharing of information in accordance with laws and regulations. For example:
4.1 With your prior consent, we may share your personal information with third parties;
4.2 Only for the purpose of external processing, we may share your personal information with third-party partners (including, without limitation, affiliates, customers, third party service providers (see the Schedule “Catalog of SDKs from Third Party and Affiliates” for details), contractors, agents, advertising partners, app developers, etc., such as the communication service providers that send e-mails or push notifications on our behalf, and the map service providers that provide us with location services, which may not be located in your jurisdiction), so that they can process the above information for us for the following purposes in accordance with our instructions, privacy policies and other relevant confidentiality and security measures: 
4.2.1 to provide you with our services;
4.2.2 to achieve the purposes set out in the section “How we use the information collected”;
4.2.3 to fulfill our obligations under this Policy and to exercise our rights; or
4.2.4 to understand, maintain and improve our services.
If we share your information with the above third parties, we will ensure the security of your information by encryption, anonymization or other means. 
4.3 As our business develops, if we share your personal information with a third party as a result of a merger, acquisition, asset transfer or other transactions, we will inform you of relevant circumstances through push notification, announcement or other means, including a notice to you of the recipient’s name and contact details in accordance with laws and regulations.
4.4 We will use the information collected for big data analysis. For example, we will use the collected information for analyzing and preparing urban heat maps or industry insight reports that do not contain any personal information. We may disclose to the public and share information with our partners that is statistically processed and does not contain any personally identifiable data in order to understand how our services are being used by our users or to inform the public of the overall trends of usage of our services.
4.5 We may disclose your personal information for the following purposes:
4.5.1 to comply with applicable laws, regulations or other relevant requirements;
4.5.2 to comply with the requirements of a court judgment, decision or other proceedings;
4.5.3 to comply with the requirements of a relevant governmental authority or other statutory authorized organizations;
4.5.4 if we reasonably believe that we need to do so in order to comply with laws, regulations or other relevant requirements; 
4.5.5 any reasonable purpose necessary for implementing the relevant service agreement or this Policy, serving social and public interests, protecting personal safety, property security or other legitimate interests of our customers, us or our affiliates, other users or our employees; or
4.5.6 after obtaining your separate consent.

5.Service-related announcements

We may send you service-related announcements when necessary (for example, when a certain service is suspended due to system maintenance). You may not be able to unsubscribe these service-related announcements which are not advertisements in nature.

6.Cookies and similar technology services;

Cookies and similar device information identification technology are commonly used in the internet. When you use our services, we may use relevant technology to send one or more cookies or anonymous identifiers (hereinafter referred to as "cookies") to your device to collect, identify, and store information about your access and use of this product, such as for statistical and analytical purposes of the website's user profile (number of visitors, page views, average browsing time, etc.). We promise not to use cookies for any purpose other than those stated in this privacy policy. At the same time, we may use cookies to showcase information or features that may interest you and optimize your advertising choices. Most browsers provide users with the function of clearing browser cache data. You can perform corresponding data clearing operations, modify your acceptance of cookies, or reject our cookies. You may not be able to use cookies dependent services or corresponding features due to these modifications.

7.Place and period of information storage

7.1 Place of information storage 
We store users’ personal information collected in the PRC within the territory in compliance with laws and regulations.
Upon obtaining your separate consent and to the extent permitted by laws, your personal information may be processed by an overseas entity (please see Section 4 “The information we share” for the type of specific data recipient). You may submit a written request to the Company for a complete list of foreign recipients of your personal information. In the meantime, the Company will take appropriate measures to ensure that your personal information remains protected, secure or in compliance with applicable foreign data protection laws. For example, the Company will take security measures such as data de-identification prior to cross-border data transfer.
7.2 Period of information storage
In general, we retain your personal information only for the shortest period necessary to achieve our purpose. However, we may change the time of storage of personal information in the following circumstances to meet legal requirements: 
7.2.1 to comply with applicable laws, regulations and other relevant provisions, or where we reasonably believe that compliance with such provisions is necessary;
7.2.2 to comply with the requirements of a court judgment, decision or other legal proceedings; 
7.2.3 to comply with the requirements of relevant governmental authorities or statutory authorized organizations;
7.2.4 any reasonable purpose necessary for implementing the relevant service agreement or this Policy, serving social and public interests, protecting personal safety, property security or other legitimate interests of our customers, us or our affiliates, other users or our employees.
In the event of cessation of operation of our services, we will notify you by way of, for example, push notifications and announcements, and will delete or anonymize your personal information within a reasonable period of time.

8.Information Security

We provide a proper security blanket for your information to prevent loss, misuse, unauthorized access or disclosure of the information.
8.1 We strictly comply with laws and regulations to protect users’ secrecy of correspondence. 
8.2 We will use a variety of security measures at a reasonable security level to ensure information security. For example, we use encryption technologies (e.g., TLS, SSL), anonymization and other means to protect your personal information.
8.3 We have established special management systems, procedures and organizations to ensure information security. For example, we strictly limit the scope of personnel who have access to information, require such personnel to comply with the confidentiality obligations and conduct review.
8.4 In the event of a security incident such as personal information leakage, we will initiate the emergency plan to prevent escalation of such security incident and notify you by push notification, announcement or otherwise. 

9.Protection of Minors

We attach great importance to the protection of minors’ personal information. Our websites and services are set up mainly for adults. Minors should not create their own personal information accounts without the consent of their parents or other guardians.
Before providing or granting access to personal information of other individuals (such as family members and other individuals) to us and/or to authorized third parties for processing, you shall ensure that such individuals understand and agree that you provide the personal information to us and/or to authorized third parties in connection with such processing, including separately consenting to each and every processing of their sensitive personal information, sharing their personal information with third parties and transferring their personal information overseas. If these individuals need to know how the Company will process their personal information, you should provide this Policy for their reference.

10.Scope of Application

This Policy applies to all services provided by FESCO Adecco, including your access to the official website of FESCO Adecco and/or log in to the relevant client to use the services provided by FESCO Adecco. Certain services, however, have specific privacy guidelines/statements that describe more specifically how we process your information in such services. If there is any inconsistency between this Policy and the privacy guideline/statement for a specific service, such specific privacy guideline/statement shall prevail. 

11.Contact Us

If you have any question about this Policy or other related matters or if you want to file a complaint or report a personal information security incident, please contact us.
Tel: 021-2312 8888
E-mail: info@fescoadecco.com

12.Update

We may revise this Policy from time to time. Without your express consent, the Company will not harm your rights provided by laws and regulations or this Policy. We will inform you of material changes by prompting a notification prominently placed on the page, sending you an email or otherwise. Please be sure to carefully read and fully understand this revised Policy and use the services we provide with a full understanding.