Datang Gaohong and its affiliated companies ( “we”, “us”, or “our”) are committed to respecting your privacy, and recognize the need for appropriate protection and management of any Personal Data that you may provide us.
This Privacy Statement explains our practices with respect to Personal Data we collect and process in connection with your relationship with us. This includes Personal Data we collect:
We encourage you to review this Privacy Statement to understand how we collect, process, use, share, and safeguard your Personal Data. If you have any questions, comments, or complaints about our practices, please contact us as outlined in the section How to Contact Us or Submit a Request at the end of this Privacy Statement.
Personal Data is any information that enables us to identify you and that is related to an identified or identifiable natural person (also known as a “Data Subject”), such as a name, an identification number, location data, or an online identifier. In some jurisdictions, data protection and privacy laws also apply to identified or identifiable legal persons.
We may collect Personal Data from you and about you from a variety of sources. We strive to only collect Personal Data that is adequate, relevant, and limited to achieve the purpose(s) for which it was collected. In addition, we strive to keep all Personal Data accurate, complete, and reliable for its intended need, and we only retain your Personal Data for as long as necessary to achieve the purpose(s) for which it was collected, as explained more fully in the section How Long We Retain Your Personal Data. Finally, we may, from time to time, provide you with supplemental information at the time we collect your Personal Data to address unique or situational collection needs.
Examples of the ways in which we collect your Personal Data include:
Information You Share with Us. We collect Personal Data when you provide it to us directly, such as through our business interactions with you; when you visit one of our office locations or Data Centers; when you provide it to us throughout an employment or pre-employment relationship; when you respond to a survey that we sent you; or when you interact with us on our website, our online customer portals, or through social media.
For example, if you visit one of our office locations, we may ask that you provide us your first and last name, business association, and email address in order to identify you as a visitor. Likewise, when you visit one of our Data Centers, we may require you to provide us your first and last name, business association, job title or position, telephone number, email address, photo, and certain biometric information, such as a hand scan or other biometric-assessment technology developed in the future that we may adopt.
Likewise, if you contact us with questions, requests, or complaints, we may collect Personal Data sufficient to answer your questions, address your requests, and/or handle your complaints. We may also require you to provide Personal Data to authenticate your identity in order to answer your questions, address your requests, and/or handle your complaints.
Information Collected through a Representative. We collect Personal Data when a representative from an organization or company with which you are associated provides it to us directly, such as through the provision of access credentials to our customer portals.
We provide several online accounts for our customers to provide a variety of services. These online accounts include the customer portals such as our Customer Portal and our partner’s Marketplace Portal, (not an exhaustive list; collectively, the “Portals”, “Customer Portal(s)” or “Portal(s)”). Each Portal requires individualized access credentials in order to log in, which are provisioned based on your first and last name, email address, business telephone number, and the company or organization with which you are associated.
For example, the Customer Portal allows registered customers to purchase additional Licensed Space and Services (as defined within relevant agreements with us) and to gain access to relevant information about the customer’s business relationship with us. If you are associated with one of our customers that has access to the Customer Portal, a representative from your organization may provide us with your first and last name, business telephone number, and email address in order for us to provide you access credentials.
Information Collected Automatically. We collect Personal Data automatically when you visit our website through logging and analytics tools, cookies, and as a result of your use of and access to our employee or customer online portals.
When you browse our website or use our online services, we utilize commonly-used logging and analytics tools, such as Google Analytics, to collect information about your device, the network used to access our online services, and information about your use of our online services (such as how you navigate and move around our website).
We also use certain technologies on our website, such as cookies, that allow us, our service providers, and other third parties to store information locally on your device, identify your device, and track your interactions and activity on our website.
Personal Data that we automatically collect may include the software and hardware attributes of the device you use to access our website and online services (such as our online employee or customer portals); unique device identification information; regional and language settings; performance data about our website and online services; network provider; and IP address (a number assigned to your device when you use the Internet).
Location Information: If you permit us to access information about your location (including global positioning system or general location information derived from the network you use to access the Services), we collect the precise or general location information provided by your device to appropriately tailor certain regional settings, such as preferred language.
Please see our Cookie Notice for more information about cookies and other web tracking technologies that we utilize; for information about how you can reject, delete, or prevent cookies from being placed on your system or device; and how you can opt out of, limit, or prevent certain web tracking technologies from collecting information about you.
Information Obtained from Third Parties. We collect Personal Data from third-party sources; through your interactions with us on social media; through industry, marketing, or trade associations events; and through database providers, public agencies or credit bureaus.
For example, if you attend an industry conference and allow the association to publish your Personal Data, we may collect information, such as your name, the business with which you are associated, your job title or position, and your email address. Likewise, if you apply for employment with us, we may perform certain diligence efforts that include collecting your Personal Data from public agencies and/or credit bureaus.
In addition, if you choose to interact with us or our partners on social media by posting to our pages, tagging us (or using certain hashtags or other identifiers) in posts, or participating in activities, we may collect Personal Data from the social media account you use to interact with us, including the name associated with the account, the account handle, recent activity, the content of any posts in which we are tagged, and other information that may be contained on your social media profile to allow us to respond to the posts and understand and engage with our audience.
You have choices about certain information we collect. When you are asked to provide your Personal Data, you may decline to do so; but if you choose not to provide your Personal Data that is necessary for us to provide any aspect of our services, you may not be able to use those services.
Moreover, to the extent that Personal Data you share with us is not your own (because, for example, you are a representative of one of our customers), you warrant that you have the right to provide such Personal Data, and you and the business with which you are associated shall be fully responsible for any liability arising from any such use of Personal Data, including indemnifying us from any such liability. If you share Personal Data with us that is not your own, you agree to inform your agents, employees, or any authorized personnel (e.g., contractors, partners, or authorized third parties) (i) that their Personal Data may be processed by us; and (ii) of their rights regarding the processing of their Personal Data in accordance with this Privacy Statement and applicable data privacy and protection law.
Finally, we may collect data that is not identifiable to you or otherwise associated with you, such as aggregated data, which is not Personal Data. To the extent this data is stored or associated with your Personal Data, we will treat it as Personal Data; otherwise, it is not subject to this Privacy Statement.
We may use your Personal Data for one or more of the following business purposes:
In addition to the uses outlined above, you may also upload additional Personal Data to certain Portals, such as a photograph of yourself or other representatives from your organization. This feature is completely voluntary, and Datang Gaohong will only use that Personal Data in connection with the purpose for which it was collected.
We will not disclose your Personal Data to any third party except as follows:
We do not sell your Personal Data to any third parties, whether for monetary or other valuable consideration, and have not done so in the prior 12 months. If we disclose your Personal Data as outlined above, we do so to facilitate the relevant services or our employment relationship with you and not for direct renumeration. Where we engage any service provider that will require access to and use of Personal Data to provide certain services for and under our instructions, we take reasonable steps to ensure such service provider complies with applicable data protection and privacy laws.
Finally, we reserve the right to disclose your Personal Data if required to do so by law, in the good faith belief that such action is reasonably necessary to comply with applicable law, or to protect the rights, property, or our safety, our employees, customers, or the public.
Due to business reasons, we may transfer your Personal Data to the Americas, EMEA, and Asia-Pacific regions, including locations where the data privacy legislation may differ from that in your country or jurisdiction. In addition, we may transfer your Personal Data to certain contracted service providers, as outlined in the section Disclosure of Your Personal Data to Third Parties, to a region where the data privacy legislation may differ from that in your country or jurisdiction.
However, we will ensure that all appropriate legitimization measures to afford such transfers of Personal Data an adequate level of protection are in place as required under applicable data protection laws.
We process your Personal Data for, or based on, one or more of the following legal bases:
We employ reasonable and appropriate physical, technical, and organizational safeguards designed to promote the security of our systems and protect the confidentiality, integrity, availability, and resilience of your Personal Data. Those safeguards include: (i) the encryption of personal information where we deem appropriate; (ii) the deployment of technical safeguards; (ii) taking steps to ensure Personal Data is backed up and remains available in the event of a security incident; and (iii) periodic testing, assessment, and evaluation of the effectiveness of our safeguards.
However, no method of safeguarding information is completely secure. While we use measures designed to protect your Personal Data, we, unfortunately, cannot guarantee that our safeguards will be effective or sufficient. In addition, you should be aware that Internet data transmission is not always secure, and we cannot warrant that information you transmit to us is or will be secure.
We retain your Personal Data for only as long as necessary to carry out the processing activities described in this Privacy Statement, including but not limited to: (i) to provide services to you or to the business with which you are associated; (ii) to enter into or perform contracts with you or with the business with which you are associated; (iii) to comply with applicable laws, regulations, rules, and requests of relevant law enforcement and/or other governmental agencies; and (4) to protect our rights, property, or safety, and the rights, property, and safety of our customers, users, and other third parties.
For our customers, upon the expiry or earlier termination of the business relationships, we will archive Personal Data to preserve evidence and/or fulfill retention requirements under applicable laws or regulations. At the end of such archiving period (namely at the expiry of applicable statutes of limitation and/or minimum record retention requirements), we will delete the Personal Data from our systems and records.
We reserve the right to change the terms of this Privacy Statement at any time. If we do make changes, though, we will take steps to indicate that the Privacy Statement has been updated on this website.
You may set most browsers to notify you if you receive a cookie or you may choose to block cookies with your browser. Please know, though, that if you choose to delete or block your cookies, you will lose the ability to save certain preferences, such as your username and password. If you delete or block your cookies, you will, for example, need to re-enter your log-in credentials to gain access to certain parts of our website upon each visit.
Depending on applicable data protection and privacy laws, you may be entitled to a variety of legal rights regarding the collection and processing of your Personal Data. You may exercise these rights, to the extent they apply to you, by contacting us as outlined in the section How to Contact Us or Submit a Request at the end of this Privacy Statement or by following instructions provided in communications sent to you.
Note, however, that we may request certain reasonable additional information (that may include Personal Data) to help us authenticate your identity, your request, and/or to clarify or understand the scope of such requests.
These rights vary depending on the particular laws of the jurisdiction applicable to you, but may include:
Where required by applicable law, we will respond to a valid request relating to your rights within one month of receipt, or within three months where a request is complex or challenging.
We respect your rights, and we will never discriminate or retaliate against you or the business with which you are associated as a result of your exercise any right outlined in this Privacy Statement or afforded to you under applicable law.
You have choices about how we communicate with you and how we process certain Personal Data about you.
To facilitate our compliance with applicable data privacy and protection laws, and to ensure strong and consistent support for our privacy practices, we have designated personnel to manage privacy compliance and to coordinate support for our customers on privacy matters.
If you have any query or complaint about this Privacy Statement or our privacy practices, or if you wish to exercise any of your rights, you may contact us at any time using the following contact information:
c/o 88 North Sichuan Road
Tower 2, 15F, Unit 1502-1504 Shanghai Landmark Center
Shanghai, People’s Republic of China, Postal Code: 200085