Privacy Policy for PRC residents

We take the privacy and security of your personal data very seriously and at all times we will comply with the prevailing laws and regulations governing confidentiality, data protection and security of information. When we say personal data, we mean any information that is about you or which can help identify you.

Your employer or former employer has an agreement to provide share plan services with one of the Computershare group entities listed below.  In this privacy policy we will call them Your Share Plan Administrator.

If you live in the People’s Republic of China (“PRC”), your personal data must be sent from the PRC to Your Share Plan Administrator for plan administration. You can find more information about how your Share Plan Administrator will use your personal data  here Computershare | Privacy.

This privacy policy gives you additional information about how your personal data will be processed in PRC and sent from the PRC. It also explains your rights over your personal data, and how you can exercise them.

Your Share Plan Administrator will be one of the following entities within the Computershare group. Check your dividend or asset statement if you're unsure who Your Share Plan Administrator is.

This privacy policy supplements the policy provided by Your Share Plan Administrator to explain how your data will be used when you access data from PRC.

Computershare International Information Consultancy Services (Beijing) Company Limited (“CIICS”). CIICS is a company established under the laws of the PRC and is a member of the Computershare Group. Its registered office is at 北京市东城区东长安街1号东方广场东方经贸城西一办公楼九层7-9室,.  CIICS is registered with the Ministry of Industry and Information Technology as the sponsor of EquateMobile for China App or EquateAccess for China App which you can use to access the apps provided by Your Share Plan Administrator.  It may handle a limited amount of personal data as part of sponsoring the app, as described below.

Your Share Plan Administrator has nominated CIICS to act as its representative when you are using the EquateMobile for China App or EquateAccess for China App.

If you have any questions about Your Share Plan Administrator’s  privacy policy or how we use your personal data, you can contact PrivacyOfficer@computershare.com.hk. However, as CIICS does not have access to your personal data, or information about your account we recommend that you contact your Share Plan Administrator using the contact details in the privacy policy.

To protect your data, the app checks your device software list to determine whether your device has been modified in ways that could compromise security. If such modifications are detected, the app will not allow a user to progress with authentication and accessing share plan information.

Additionally, the app will collect limited information such as your language preferences,  timestamps and your IP address in PRC.

All other personal data required that you provide or are provided by your employer to manage the Share Plan will be processed by Your Share Plan Administrator in accordance with its privacy policy.

As sponsor of the EquateMobile for China App or EquateAccess for China App CIICS does not process the data in your account. Your Share Plan Administrator will not be based in the PRC and will be based in a country where data protection laws and standards differ from those in the PRC, including the European Economic Area, Canada, Australia, and the United States.

Where you provide your details to Your Share Plan Administrator in the EquateMobile for China App, you do so based on the terms and conditions of the EquateMobile for China App or EquateAccess for China App. In order for the Share Plan Administrator to fulfil its contract with you, your data must be sent to Your Share Plan Administrator. Your Share Plan Administrator will ensure adequate measures are in place to safeguard your personal data and to ensure you can exercise your rights effectively. If you would like more information about transfers to other countries and the ways in which we protect your personal data, please contact Computershare’s Group Data Protection Officer by emailing dataprotection@computershare.co.uk.

Information about installed packages and apps will only be held for the duration of the session.

Your Share Plan Administrator will keep other personal data for as long as it needs to for the purposes for which it was collected or (if longer) for any period for which Your Share Plan Administrator is required to keep personal data to comply with its legal and regulatory requirements.

When Your Share Plan Administrator handles your personal data, in most cases it does so on behalf of your employer.  Your Share Plan Administrator may therefore forward your request to your employer.

Your rights are detailed in Your Share Plan Administrator’s privacy notice (see above) and can be exercised either by contacting CIICS who will forward your request to Your Share Plan Administrator, or directly via Your Share Plan Administrator.

In summary your rights are:

You may ask for a copy of the personal data we hold about you, or about a near relative where they are deceased,

We try to ensure all of your personal data is complete and accurate. If you find any inaccuracies or if your details change, or you wish to correct the data of a deceased near relative please notify Your Share Plan Administrator promptly.

You may ask us to erase or restrict use of your personal data, or the personal data of a deceased near relative. If you do, we will comply with your request unless there is a legal reason for us not to (for example, if a law says we must retain records of share dealing for a fixed period and to do so we must retain your personal data, or if it is necessary for us to retain the personal data for the purpose of performing a contract with a share issuer).

You have a right to request that your personal information is transferred to a personal data handler that you delegate. We will work with your employer to establish what you can practically transfer

You may object to our processing of your personal data. If we are able to do so, we will stop processing your personal data promptly.

Please note that where you contact us to exercise your data protection rights we may ask you to provide a form of identity verification before we can process your request.

If you have any complaints about the way we use your personal data please contact our Data Protection Officer who will try to resolve the issue.

You also have the right to complain to the data protection supervisory authority in your country. If you need more information about how to contact your local data protection authority please let us know by contacting our Data Protection Officer.