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People & Projects Group Privacy Notice and Cookie Policy
PRIVACY NOTICE

People & Projects is committed to protecting your personal data. This privacy notice describes how People & Projects collects, uses and shares the personal data you provide to us or that we collect during the course of our business activities, including from our website.

INTRODUCTION

This privacy notice is issued on behalf of People & Projects Ltd and other companies within the People & Projects Group. Accordingly, references to “People & Projects”, we”, “us” or “our” in this privacy notice are to the relevant company in the People & Projects Group responsible for processing your data. A list of People & Projects companies can be found at the bottom of this page.

People & Projects operates in jurisdictions that are outside the European Union, some of which have not been deemed adequate by the European Commission (namely China, Hong Kong, Singapore and Japan). Where we share your data with People & Projects Group companies we do so on terms where such data is to be kept secure and confidential.

People & Projects may collect information from you through your use of our websites, when you request information from us or otherwise in the course of our business.

People & Projects’ Data Protection Officer (DPO) may be contacted in relation to questions arising in relation to this privacy notice or if you have any questions in relation to exercising your legal rights. The DPO may be contacted on the details below:

Email address: DPO@Pndp.net Postal address: People & Projects House, Unit 305-7, 3/F, Laford Centre, 838 Lai Chi Kok Road, Cheung Sha Wan, Kowloon Hong Kong Telephone Number: +852 2915 8198

THE DATA WE COLLECT ABOUT YOU

Personal data, means any information about an individual from which that person can be identified it includes information that you provide to us or which we gather in the course of operating our business.

People & Projects may collect various types of personal data about you including:

Identity data (which may include your title, name and passport/driving license/national identification card information, personal data relating to convictions, politically exposed person (PEP) status, personal data available in the public domain and such other information as may be necessary for People & Projects to provide our services meet our legal obligations as to the prevention and detection of fraud, money laundering and other crimes);
Contact data (which may include postal address, email address and telephone numbers);
Professional/employment data (which may include your education background, professional qualifications, employment, details of directorship and other offices which you may hold);
Financial data (which may include sources of wealth, details of your assets, shareholdings and beneficial interest in assets, bank account details, credit history);
Family relationships data (which may include your marital status, the identity of your spouse/partner and any children you may have);
Data collected to enable us to meet our contractual obligations (which may include health, family matters, individuals connected to you, religion, race or ethnicity, political opinions);
Technical data (which may include your Internet Protocol (IP) address, how you use our website, browser type and version, time zone setting and location, and other technology available from the devices you use to access our websites);
Marketing and communications data (which may include your preferences in receiving marketing from us and our third party providers and your communication preferences).

If you apply for a position with People & Projects either through our website or directly via email or post we may collect personal data relating to your past employment, education and professional qualifications, your nationality and immigration/residential status, opinions from third parties about you (such as references), publicly available information including but not limited to information on social media accounts and any other personal data which may be gathered during the recruitment process.

IF YOU FAIL TO PROVIDE PERSONAL DATA

Where People & Projects is required to collect personal data by law or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or propose to enter into with you.

HOW IS YOUR PERSONAL DATA COLLECTED?

We use different methods to collect data from you and about you including but not limited to:

Direct Interactions. You may give us your information by filing in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
• apply for our services;
• subscribe to our services or publications;
• request material be sent to you.

Third Parties or Publicly Available Sources. We may receive personal data about you from various third parties and public sources including but not limited to:
• personal data gathered through client due diligence undertaken to meet regulatory requirements (including through credit reference agents);
• personal data from publicly available sources such as a Companies Registry;
• personal data received in the course of dealing with advisors, lawyers, regulators, official authorities and service providers;
• our clients in connection with the services we are providing;
• legal and/or financial advisors;
• other financial services providers;
• personal data on potential candidates may be obtained from recruitment agencies, past or current employers, educational institutions and/or professional bodies;
• analytics providers such as Google based outside the EU.

INFORMATION THAT WE COLLECT THROUGH OUR WEBSITE You are not required to provide any personal data in order to access this website.

You may voluntarily choose to provide personal data by signing up for news letters or other publications.

Our websites collect the domain names, IP addresses, user statistics, analytics and browsing history of all visitors. For further information please see our Cookies Policy below. People & Projects uses this data to promote our services.

HOW PEOPLE & PROJECTS USE YOUR INFORMATION

People & Projects provide corporate, private client and fund administration services to our clients and we use your personal data for those purposes. The purposes for which we use your personal data should be clear when we collect that data. People & Projects will use your personal data to:

• perform a contract that we are about to enter into or have entered into with you;
• comply with a legal or regulatory obligation;
• respond to requests, enquiries or complaints received from you or someone connected to you;
• establish, exercise or defend legal proceedings and/or People & Projects’ legal rights;
• conduct administrative or operational processes within People & Projects;
• compile statistics in relation to the use of our websites;
• send you marketing material;
• for other legitimate business purposes;
• review and process any application you make in relation to recruitment.

People & Projects do not generally rely on consent as a legal basis for processing your personal data other than in relation to sending marketing communications to you via email. You have the right to withdraw consent to marketing at any time by contacting us.

DISCLOSURE OF YOUR PERSONAL DATA

People & Projects may share your personal data with the parties set out below for the purposes listed above.
Internal. People & Projects shares personal data with other companies in the People & Projects Group acting as joint controllers or processors and who are based in Beijing, Changshu, Guangzhou, Hong Kong and Shanghai, Shenzhen, Singapore and Tokyo.

External. People & Projects may share your personal data with the following third parties:
• service providers acting as processors who provide IT and system administration services;
• professional advisers acting as processors or joint controllers including lawyers, bankers, investment advisers, auditors, brokers, insurers and accountants who provide, legal, banking, advisory, audit, insurance and accounting services;
• tax authorities, regulators and other authorities acting as processors or joint controllers who require reporting of processing or information for compliance;
• fraud prevention agencies acting as joint controllers;
• courts or to comply with legal obligations such as combating money laundering and terrorist financing where such parties would be acting as joint controllers;
• organisations and individuals if you have applied for a role with People & Projects, in order for us to obtain references and confirmation of details.

INTERNATIONAL TRANSFERS

Whenever People & Projects transfers your personal data outside of the European Economic Area (EEA), we will ensure a similar degree of protection is afforded to such data by ensuring that at least one of the following safeguards is implemented:

• People & Projects will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission;
• People & Projects may require certain organisations to use specific contracts approved by the European Commission which give personal data the same protection it has in Europe;
• Where we use providers based in the United States (US), People & Projects may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US. People & Projects may rely on other circumstances where the law permits the transfer for example where the transfer is necessary for the performance of a contract. People & Projects will ensure any transfer of your personal data will be compliant with applicable data protection laws. Please contact the DPO if you require further information on the specific mechanism used by People & Projects when transferring your personal data outside of the EEA.

MARKETING

People & Projects will provide you with choices regarding certain use of your personal data, particularly around marketing and advertising. People & Projects may contact you by email or other means to inform you about news, market updates, services or events which we think may be of interest to you. You have the right to ask People & Projects to stop sending you marketing messages at any time by adjusting your marketing preferences or by following the opt-out links on any marketing message sent to you or by contacting us at any time.

DATA SECURITY

People & Projects has put in place appropriate security measures to protect your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

People & Projects has put in place procedures to deal with any suspected personal data breach and we will notify you and any applicable regulator of a breach where we are legally required to do so.

HOW LONG WILL YOU USE MY PERSONAL DATA FOR?

People & Projects will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

YOUR LEGAL RIGHTS

Under certain circumstances, you have rights under data protection laws in relation to your personal data we process, you have the right to:
• access your personal data;
• rectify your personal data;
• restrict the use of your personal data;
• request your personal data is erased; and
• object to processing of your personal data.

Where we have relied on consent to process your personal data, you have the right to withdraw consent at any time.

If you wish to exercise any of the rights set out above please contact the DPO.

You also have the right to make a complaint at any time to a supervisory authority for data protection issues.

Hong Kong – Office of the Privacy Commissioner for Personal Data (https://www.pcpd.org.hk/)

Singapore – Personal Data Protection Commission (https://www.pdpc.gov.sg/)

You may also contact the authority in the EU member state of your usual residence or place of work.

We would, appreciate the chance to deal with your concerns before you approach any regulatory authority so please contact us in the first instance.

CHANGES TO THE PRIVACY NOTICE AND YOUR DUTY TO INFORM US OF CHANGES

We may make changes to this privacy notice from time to time. You should look at this page to ensure you are comfortable with any changes. This version was last updated on 22 May 2018.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

PEOPLE & PROJECTS GROUP COMPANIES

China

People & Projects (Shanghai) Business Consultancy Co Limited is a data controller and has three registered offices:
1. Room 8F8th Floor, Hi-Tech Kingworld (West Building), No.668 Beijing Road (East), HuangPu District, Shanghai
2. Room 4C08, 4/F Tianjun Building, No. 3001 Dongmen South Road, Luohu District, Shenzhen
3. 518001, Room 1006, 10th floor, East Tower, Renfeng Building No. 490 Tianhe Road, Tianhe District Guangzhou, 510000

People & Projects (Suzhou) Business Consultancy Co Limited is a data controller and has two registered offices:
1. Room 1801, 1802,1806, no.180-1 Binjiang Overseas Building Jingang Road, Changshu Economic and Technological Development Zone, Changshu City of Suzhou, Jiangshu Province, PRC
2. Room 8F, 8th Floor Hi-Tech Kingworld (West Building), No.668 Beijing Road (East), HuangPu District, Shanghai

People & Projects (Beijing) Business Consultancy Co Limited registered office: Unit 1518 Zhongyu Plaza, A6 Gongti North Road, Chaoyang District, Beijing, China

Hong Kong

The following People & Projects group companies are data controllers and have the registered address of Unit 305-7, 3/F, Laford Centre, 838 Lai Chi Kok Road, Cheung Sha Wan, Kowloon Hong Kong:

• People & Projects Limited
• Modus 3 Limited
• P-Comsec Limited
• P&P-Iberam Limited


Singapore

P & P Singapore Pte Limited has the registered address of 16 Raffles Quay #33-02, Hong Leong Building, 048581, Singapore

Spain

People & Projects Limited has a registered office at C/Buenos Aires, 60, 4º 1ªA, 08036 Barcelona, Spain

Italy

P&P Singapore Pte Limited has a registered office at Corso Venezia 43 20121 Milano Italy



PEOPLE & PROJECTS COOKIE POLICY

Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our website.

A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer's hard drive.

We use the following cookies:

Analytical/performance cookies. They allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.
Functionality cookies. These are used to recognise you when you return to our website. This enables us to personalise our content for you and remember your preferences and interests (for example, your choice of language or region).
Targeting cookies. These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website and any marketing displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.

Please note that third parties (including, for example, advertising networks and providers of external services like web traffic analysis services) may also use cookies, over which we have no control.

Our website uses Google Analytics, a web analytics service provided by Google Inc.

Google Analytics uses cookies to help website operators analyse how users use the website. The information generated by the cookie about your use of the website (including your IP address) will be transmitted to and stored by Google on servers in the United States. Google will use this information for the purpose of evaluation your use of our website, compiling reports on website activity for website operators and providing other services relating to website activity and internet usage.

Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google's behalf. Google will not associate your IP address with any other data held by Google. By using our website, you consent to the processing of data about you by Google in the manner and for the purposes set out above. To prevent Google Analytics cookies being set, you may install the Google Analytics Opt-Out Browser Add-On.

You block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our website.

All cookies persist until deleted but session cookies expire when you close your browser.