Privacy notice – Mainland China
This privacy policy applies when the representative offices and consultancy service provider of Johnson Stokes & Master (“JSM”) in Mainland China (the “JSM Mainland China Entities”, “we”, “us” or “our”) collect personal information or you, your employer or relevant third parties provide your personal information to the JSM Mainland China Entities. Please refer to the Legal Notices on JSM’s website for more details about us.
This privacy policy supplements the information contained in JSM Privacy Notice located at www.jsm.com (the “JSM Privacy Notice ”).
Transferring and Sharing of your information
We may transfer your personal information out of Mainland China for the following purposes:
- to provide client services and respond to enquiries,
- to fulfil compliance and legal obligations,
- to manage our business and client relationships, and
- to market our business and services, such as providing information about our events or services, client conferences, seminars or networking events.
The information may initially be transferred to a Hong Kong service company established by JSM named Sekots & Co., Limited, and located on the 16-18th Floors, Prince’s Building, 10 Chater Road, Central, Hong Kong (the “Overseas Recipient”), which provides the infrastructure located in Hong Kong for us to store and manage your personal information.
As explained in Regulatory and Contact Information section of the JSM Privacy Notice, JSM is temporarily associated with Mayer Brown Hong Kong LLP (“MBHK”). Exchange of data will be required with certain Mayer Brown Practices as part of our regular business. To the extent required, your personal information transferred to the Overseas Recipient may be provided to or accessed by JSM, MBHK, Mayer Brown LLP in Chicago (“MB-US”) and Mayer Brown International LLP in the UK (“MB-UK”). JSM and these Mayer Brown entities may process your information for the purposes of enabling the JSM Mainland China Entities to achieve the abovementioned purposes. The contact information of JSM, MBHK, MB-UK and MB-US can be found in the Legal Notices of JSM and Mayer Brown.
The type of personal information transferred outside Mainland China may include:
- basic personal information such as names, contact details and information about family relationships (excluding sensitive personal information),
- personal identity information such as your ID card and passport,
- personal education and work information such as personal occupation, position and department,
- personal financial information such as your bank account information and source of funds collected for business acceptance purposes and anti-money laundering and terrorist financing requirements,
- personal communication information such as communication records, the content of emails, and including technical data relating to your interactions or communication with us,
- personal information pertaining to transactions, proceedings, or other legal matters, such as those contained in documents and other materials related to transactions, litigation, arbitration, dispute resolution, and tax registration,
- marketing data, such as information about individuals participating in events, meetings, in-person conferences, interests and preferences, and
- other information: trade union membership information.
In very limited circumstances, we may collect and process sensitive personal information (including sensitive personal information that you have voluntarily provided to us) if it is necessary to achieve the purposes set out above. This may include your ID numbers and photos (without specific technical processing) from your identification documents and financial data, which are necessary for verification of your identity and complying with business intake procedures. Additionally, if necessary for a specific service we are providing to you, we may also process other sensitive personal information. The types of sensitive personal information we process will depend on the requirements of the specific matters.
Without providing your relevant personal information, including sensitive personal information, we may not be able to respond to your request or provide you with our legal services.
If you provide us with personal information relating to other persons (such as family members, work colleagues, employees, etc.) located in Mainland China, you are responsible for ensuring the relevant individuals are made aware of the terms of this privacy policy and the JSM Privacy Notice and that you are legally authorised or entitled to provide us with their personal information. You are also responsible for ensuring that their personal information is accurate and up-to-date, and you transfer the information to us in compliance with applicable data protection laws.
Your rights in connection with personal information
As a data subject in Mainland China, you have rights according to the PRC Personal Information Protection Law (“PIPL”) which include the following:
- to access your personal information where applicable,
- to request deletion of your personal information, and
- to withdraw consent to our processing of your personal information.
We will endeavour to support the exercise of your rights in accordance with applicable law. Please note that exercising certain rights may affect the services we can offer and we may be subject to certain constraints. For example, if you would like to delete your personal information provided to us, but the retention period prescribed by the applicable laws and regulations has not expired, or it is technically difficult to delete the personal information, we will cease the processing of the personal information, except for the storage and any necessary measure taken for security protection.
If we process your personal information based on your consent, you will have the right to withdraw your consent at any point. The withdrawal of your consent does not invalidate the processing activities that were carried out based on your consent prior to the withdrawal.
Contact Information
If you wish to exercise any of your data subject rights, you may submit your request via email to our privacy team by using the privacy@jsm.com or use the contact details provided here to reach the JSM Mainland Entities and the Overseas Recipient.
In order to facilitate this process and to enable us to assist you, when you make a request please specify the nature of your request, and provide your name, e-mail, telephone number, and proof of identity. We will use this information solely to validate your request by matching it with our records.
