* DCP Data Protection Policy
TABLE OF CONTENTS
1. INFORMATION WE COLLECT
2. HOW WE USE YOUR INFORMATION
3. WHO WE SHARE YOUR PERSONAL INFORMATION WITH
5. OUR DATA SECURITY
6. DATA RETENTION
7. EU/UK INFORMATION
8. CALIFORNIA RESIDENTS
10. QUESTIONS AND COMMENTS
1. INFORMATION WE COLLECT
In general we may collect two different types of information from you when you visit the Site.
· Contact Information: We collect information you voluntarily provide to us when you choose to interact with DCP, such as providing a name, email address or phone number when using the contact options provided on this Site.
· Website Usage and Device Information: We also collect information through technology, such information includes collecting your IP address when you visit the Site, the type of Internet browser you are using, the pages you visited on the Site, frequency of visits, or how you arrived at our Site. See also the section on Cookies below.
2. HOW WE USE YOUR INFORMATION
We use personal information collected via our Site for a variety of business purposes described below. Please refer to the EU/UK Information, California Residents, Singapore and Mainland China sections for more information on the applicable legal basis.
We use the information we collect or receive to:
- send you marketing communications to promote our services and financial products and invite you to business events.
- provide you with the services or products you requested.
- provide the company for which you are working with the services or products requested.
- request feedback and to contact you about your use of our services or Site.
- store cookies on your device as described in the section on Cookies below.
- enforce our terms, conditions and policies for business purposes, contractual or legal reasons.
- respond to legal requests and prevent harm. If we receive a subpoena or other legal request, we may need to inspect the data we hold to determine how to respond.
- respond to user inquiries.
- comply with legal obligations to which we are subject.
3. WHO WE SHARE YOUR INFORMATION WITH
We do not sell your personal information to third parties.
We may share your personal information with recipients acting as processors on our behalf, including our affiliates and our services providers (i.e, providers of hosting and maintenance services established in Mainland China, the EU and in countries mentioned in Section 7 below) which require access to such information to do that work.
We may disclose your information to other controllers where we are legally required to do so in order to comply with applicable law, governmental requests, a judicial proceeding, court order, or legal process, such as in response to a court order or a subpoena (including in response to public authorities to meet national security or law enforcement requirements). We may also share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
Some cookies are strictly necessary for the Site to function. If these cookies are blocked, certain aspects of the Site may not work. Cookies essential to Site functionality include:
Subject to your consent (if required in your jurisdiction), other cookies permit us to monitor Site traffic so we can improve performance of the Site. Cookies related to Site performance include:
The cookies will be kept for a period of thirteen (13) months.
5. OUR DATA SECURITY
We have implemented appropriate technical and organizational security measures designed to protect the security of any personal information we process, including from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. We limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to access it and require such parties to process your personal information in a confidential and secure manner. However, please also remember that we cannot guarantee that the internet itself is 100% secure. You should only access the Site within a secure environment.
6. DATA RETENTION
With respect to the services or products provided to you, we will keep your personal information during the period of our contractual relationship, extended by the applicable limitation period.
With respect to the services and products provided to our business clients, we will keep your personal information during the period of our contractual relationship with the company for which you are working, extended by the applicable limitation period. With regard to marketing communications with prospects, we will keep your personal information for three years after the last correspondence with us.
With respect to the processing carried out in order to enforce our terms, conditions and policies or to respond to legal requests and prevent harm, we will keep your personal information for the time of the relevant dispute or statute limitation period.
As to the processing carried out in order to comply with a legal obligation, we will keep your personal information for the duration of such obligation.
Upon expiry of the applicable data retention period, we undertake to erase or irrevocably anonymize the relevant personal information.
7. EU/UK INFORMATION
Data Subject Rights
When the General Data Protection Regulation ("GDPR") applies, you have various rights in relation to the processing of your personal information depending on the relevant situation:
Access to personal information processed concerning you;
Correct inaccurate personal information;
Delete any personal information concerning you;
Restrict processing of your personal information;
Receive your personal information provided to us in an interoperable format (data portability);
Object to the processing on grounds relating to your particular situation.
Legal Basis for Processing
When the GDPR applies, we rely on the following legal basis when we process your personal information:
● Contractual Necessity: We process personal information for the management of our relationship on the basis of your use of the Site, the services or products we provide you and communicate with you in that respect.
● Legitimate Interest: We process personal information based on our legitimate interests which consist in: (i) providing services or financial products to the company for which you are working and managing our relationship with this company; (ii) responding to your queries; (iii) migrating your environment, including your personal information, to another legal entity if we change of distributing partner; (iv) complying with non-EU laws, responding to requests from, and other communications with, competent public, governmental, judicial or other regulatory authorities and responding to valid legal process, investigate or participate in civil discovery, litigation, or other adversarial legal proceedings; and (v) protecting your rights, property or security and ours, including by investigating potential violations of or enforcing our terms, conditions and policies.
● Legal Obligations: We process personal information to comply with the legal obligations to which we are subject (i.e, to detect abuse, fraud and illegal activity).
Is any of your personal information transferred internationally?
8. CALIFORNIA RESIDENTS
If you are a California resident, you may have certain additional rights with respect to your personal information. The California Consumer Privacy Act of 2018 ("CCPA") provides California residents the right to request, with respect to covered personal information:
● Disclosure of our practices: The categories of personal information we collect, the categories of sources from which the personal information is collected, our purpose(s) for collecting the personal information, and the categories of third parties with whom we have shared personal information.
● Access to the categories and/or specific pieces of your personal information we have collected.
● Deletion of any of your personal information we have collected.
● To opt out of "sale": request that your personal information not be sold to third parties. As noted above, we do not sell personal information to third parties, and therefore do not provide an option to opt out of the sale of your personal information.
As required by the CCPA, we will not discriminate against you for exercising any of these rights
California's Shine the Light Law
California Civil Code Section 1798.83, also known as “Shine The Light” law, permits California residents to annually request, free of charge, information about the disclosure of their personal information (if any) to third parties for the third parties' direct marketing purposes in the preceding calendar year. We do not share personal information with third parties for such purposes.
Do-Not-Track is an initiative that developed a signal that an Internet user may activate to inform websites that the user does not want to have their data tracked. The Site does not currently respond to such signals.
If you are located in Singapore, please note the following:
Consent: Where you choose to interact with DCP to provide a name, email address or phone number when using the contact options provided on this Site, we will seek your consent to collect such information. In such a case, you will have the following rights:
Withdrawing consent: Where we rely on your consent to collect, use and/or disclose your personal information, your consent will remain valid until you choose to withdraw such consent in writing. Please understand that the collection, use and/or disclosure of your personal information may be necessary for us to respond, process and handle your requests, queries, feedback and suggestions. If you withdraw your consent to any or all use of your personal information, depending on the nature of your request, we may not be in a position to continue to provide our services to you. However, please note that withdrawing your consent will not affect our right to continue collecting, using and/or disclosing your personal information where we are permitted or required to do so without consent under the applicable laws.
Transfer of personal information outside Singapore: Where we are required to transfer your personal information out of Singapore for any of the purposes described in Section 2 above, you consent to us so transferring your personal information outside Singapore. We will take steps to ensure that your personal information is protected to at least the same standard as that granted under the Personal Data Protection Act 2012, particularly to jurisdictions such as Mainland China or Hong Kong which may not have an adequate level of protection. Where transfers to outside Singapore are based on your consent, you may withdraw your consent at any time. However, please understand that we may no longer be in a position to continue to provide certain or all of our services to you.
10. MAINLAND CHINA
If you are located in Mainland China, please note the following:
Basis for processing: We may rely on the following legal basis for handling your personal information:
Consent: We rely on your prior consent in order to handle your personal information, including sending you marketing communications about our services and products, and to invite you to business events.
Contractual necessity: We may handle your personal information where necessary to conclude or fulfill a contract in which you are an interested party;
Statutory obligations: There may be circumstances in which we may handle your personal information where necessary to fulfill statutory duties, responsibilities or obligations;
Public health grounds: We may handle your personal information where necessary to respond to sudden public health incidents or protect natural persons' lives and health, or the security of their property in emergency conditions;
Public interest grounds: We may handle personal information within a reasonable scope to implement news reporting, public opinion supervision, and other such activities for the public interest;
Handling of personal information disclosed by persons themselves: We may handle personal information disclosed by persons themselves or otherwise already lawfully disclosed, within a reasonable scope in accordance with the provisions of the Personal Information Protection Law;
Other circumstances: We may also handle your personal information in other circumstances provided in laws and administrative regulations.
Your rights: You have the following rights under the Personal Information Protection Law concerning the personal information that we hold:
Right to know. The right to know and make decisions relating to your personal information, and to limit or refuse the handling of your personal information by others, unless laws or regulations state otherwise.
Right of access. The right to obtain access to your personal information and to copy your personal information except for where applicable laws or regulations provide for the confidentiality of such information.
Right to withdraw consent. If we are relying on your consent to process your personal information, you have the right to withdraw your consent at any time.
Right to correction. The right to obtain correction / completion of your personal information without undue delay where that personal information is inaccurate or incomplete.
Right to erasure. The right to request us to erase your personal information in the following situations:
when it is no longer necessary for the purposes for which we have collected it;
the purpose for which we have collected it is has been achieved or is impossible to achieve;
we have ceased to provide goods or services to you and the legal retention period for retaining such data has expired;
you have withdrawn your consent and no other legal ground for the processing exists;
the processing is unlawful;
and as required under other applicable laws or regulations.
Right to portability. The right to move, copy or transfer personal information from one organization to another.
Right to object: You have the right to object to the processing of your personal information for compelling and legitimate reasons if the processing is based on our legitimate interest.
If you wish to exercise one of these rights, please contact us using the contact details listed below.
When we share your personal information with third parties, your personal information may be transferred to and/or made accessible from countries outside of Mainland China. In such circumstances, we will enter into model contractual clauses as adopted by the Cyberspace Administration of China, as applicable, or rely on alternative legal bases, and implement mandatory measures to act in accordance with applicable laws (for example, to disclose additional required information to you when transferring your personal information out of Mainland China).
11. QUESTIONS AND COMMENTS
If you have any comments or questions about our privacy practices or your experience with the Site, or wish to exercise any of the rights described above, please contact us at firstname.lastname@example.org,53/F, China World Tower A 1 Jianguomenwai Ave., Chaoyang Dist., Beijing, China 100004.
You can also contact our Data Protection Officer by sending an email to the following address: Owen.email@example.com.