Personal data includes any information that can be used to identify a person, except erased data (anonymous information).
2. Data holder—About us
3. Legal basis for processing personal data
The Data Protection Law specifies the various legal grounds that organizations can collect and process personal data,including:：
Under certain circumstances, we are required to collect your personal data in compliance with contractual obligations. For instance, we collect your (personal/business) information and contact details when you have been identified as a new customer. If you are unable to provide such information, we may not be able to enter into a contract or perform the contract with you or your organization.
We may be required by law to collect and process your personal data. For instance, we may request you to provide personal information in accordance with money laundering laws or legislation related to recruitment and provision of services. If you are unable to provide such information, we may not be able to enter into a contract or perform the contract with you or your organization.
Lawful rights and interests
Under certain circumstances, we are required to use your personal data to protect our lawful rights and interests in our business operations without materially affecting your rights, freedoms or interests. For instance, your personal data may be used to ensure there is no conflict of interest, and our contract with you or your organization does not violate BQ’s contractual obligations with any third parties.
We will process your personal data after obtaining your consent, which you have the right to withdraw any time. When we process sensitive personal data related to your health or religious beliefs, we shall seek separate consent for using such information.
4. Types of personal data we may collect
We may collect your personal data when you use our services and website, contact or request information from us, or through your correspondences with our employees and customers.
The personal data we process includes, but is not limited to:
• Contact details, such as your name, the company you work for, job post, your relationship with a specific person,mailing address, email address and phone number;
• Identity and background information provided by you or collected by us during the business acceptance process, which may include your full name, photo identification and gender;
• Technical data, such as information we collect when you visit our website;
• Information provided to us for attending conferences and BQ events (including dietary requirements);
• Personal data provided to us by or on behalf of our customers, or collected by us during the provision of services.
We collect your personal data for various reasons, including:
• Facilitate provision of services;
• Confirm your identity;
• Develop and promote new services;
• Abide by any applicable laws or court orders;
• Perform our agreements;
• Recruit new employees.
Online Data Collection—BQ Websit
Processing of personal data for marketing purposes
We may use various online methods to collect your data, such as through your use of our website. On some sections of our website, you may be invited to subscribe to publications, newsletters and company announcements, receive invitations to events, seminars and online events, as well as participate in surveys. If you accept these invitations, we may collect data such as your name, company email address, job post, name and address of organization. We believe it is necessary to collect such personal data to protect our lawful rights and interests in our business operations without materially affecting your rights, freedoms or interests.
If you are interested in applying for BQ vacancies through the résumé
submission channels on our website, you should provide details about your education background, work experience and other relevant information. This allows our recruitment team to make an informed decision on accepting your application. We believe it is necessary to collect such personal data to protect our lawful rights and interests in our business operations without materially affecting your rights, freedoms or interests. We will not process any sensitive personal data unless permitted by relevant laws or with your express consent.
Offline data collection
We use various methods to collect your personal data, including direct interaction (such as providing us with your business card at a conference or event), third-party sources such as tax authorities, or publicly available sources.
BQ mainly works with corporate entities rather than individual customers. To maintain the confidentiality of customer data, it may not be appropriate for us to provide customers’ employees, competitors and third parties with privacy protection statements that describe how we handle their personal data. We believe the processing of such information is necessary for us to protect our lawful rights and interests, as well as comply with statutory and contractual obligations.
How do we protect your data?
We are committed to ensuring that your data stays safe and secure. To prevent unauthorized access or disclosure, we have
put in place appropriate technical and administrative procedures to protect your personal data. Our systems are
regularly monitored for potential risks and attacks, while penetration tests are conducted to further enhance security.
Access to personal data on a need-to-know principle is restricted for employees, agents, contractors and other third parties. Procedures are in place to identify and respond to data security breaches. As required by law, we will notify you and data protection authorities on data breaches.
6. How long will your personal data be kept?
We will keep your personal data for as long as necessary to meet any legal, accounting or reporting requirements.
BQ has established a file retention and deletion policy. Your data will be erased or anonymized (for example, aggregated with other data for analysis and business planning in an unidentifiable form) at the end of retention period. In certain circumstances, you may request us to erase your data.
7. Who do we share your personal data with?
During the provision of services, BQ may share your personal data with a number of third parties (who may act as data processors or joint data controllers). These third parties may include, but are not limited to:
• Various professionals, including lawyers, accountants and tax advisers;
• Regulators or tax authorities.
BQ requires all third parties acting as data processors on our behalf to provide full assurance that they will implement appropriate technical and organizational measures to process personal data for specific purposes only, and ensure data confidentiality.
8.How do we process your data?
To facilitate business operations, BQ may transfer, store and process your information among its affiliates,subsidiaries or third parties as stated in Article 7.
Personal data collected on BQ website
BQ uses its own servers in mainland China to manage and maintain the website. The personal data provided to us through our website will be stored in our information management system.
9. What are your data privacy rights?
You hold a number of data privacy rights, which are subject to certain exemptions and vary in each jurisdiction in which BQ operates.
10. Right of access to personal data
Subject to exceptions, we will provide a copy of your personal data within the timeframe prescribed by relevant laws.
Right to rectification
You have the right to rectify inaccurate personal data.
Right to erasure/ Right to be forgotten
You can make a request to erase or remove personal data under certain circumstances. If we process your personal data based on our own lawful interests, you may request to stop processing your data for personal reasons. We are required to fulfill this request unless there are more important legal grounds to continue processing your personal data.
Right to data portability
Under certain circumstances, you may have the right to access your personal data in a structured, commonly used, machine-readable format and to reuse it elsewhere, or request to transfer the data to a third party of your choice.
Right to objection
You have the right to object to our processing of your personal data under certain circumstances. You have the right to file an objection at any time if your personal data is processed for direct marketing purposes.
Right related to automated decision-making and profiling
Under certain circumstances, you have the right not to be bound by decisions based on automated processing or profiling that would have a legal or similarly significant effect on you.
To ensure data confidentiality, we will require you to prove your identity before proceeding with any request. Third parties will be required to prove they have been authorized to submit a request on your behalf.
11. Links to third-party websites
Our website may contain links to third-party websites, plug-ins and applications. Clicking on or enabling such links may allow third parties to collect or share information about you. If you access links to any third-party websites, please note that these websites have their own privacy statements or policies, and we are not responsible or liable for their data processing activities.
12. Contact us
Policy sets out most of your rights under specific laws, but may not include all of your rights.
You have the right to file complaints to data protection authorities at any time. However, we would like to be given the opportunity to learn about your concerns before you get in touch with the authorities.
It is very important to ensure the personal information we hold about you is accurate and up-to-date. Please inform us of any changes to the personal data provided to us.