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Introduction
This privacy statement describes how CHINA ENTERCOM (hereinafter defined under "About Us") collects and protects your personal data. CHINA ENTERCOM are committed to respecting your online privacy and knowing that providing effective protection for your personal information is the cornerstone of the healthy and sustainable development of our business. 
We are obliged to protect your personal information and to provide channels for you to manage your personal information collected by us (or third party that may be on half of us bond by contract).

This privacy statement applies to all personal data that is collected and processed by us when you visit this website and/or use the products and services offered on this website and interact with us through social media and other means. For a specific product of CHINA ENTERCOM, if there is a separate privacy policy in place, then it should take precedence over this policy. Any content not covered by such product privacy policy shall be supplemented by the contents of this policy. This Privacy Policy aims to help you understand what personal information we will collect, why we collect it, what we will do with it, and how to protect it.

Before you start using our products and services, you must carefully read and understand this policy to ensure that you fully understand and agree to its contents. If you have any questions, comments or suggestions on the contents of this policy, you can contact us through the contact information 
at the end of this policy.

About Us
CHINA ENTERCOM Enterprise ICT Solutions Limited (referred to as "CHINA ENTERCOM" or "We") is one of the subsidiaries of The CITIC Group. Our services cover most of the key areas of enterprise ICT, including CeOne-CONNECT Private Network Services, TrustCSI Information Security Management Services, SmartCLOUD Cloud Computing Management Services and DataHOUSE Cloud Data Center Services. These four flagship products and a series of value added management services can be integrated with each other, and cooperate with network operation center (NOC), security operations center (SOC) and cloud computing operation center (COC) to become a strong backup for enterprise users. With innovative ICT Integrated solutions, CHINA ENTERCOM received various awards. Its excellent services have been helping customers to succeed in digital transformation, earning itself increasingly pronounced international recognition.

CHINA ENTERCOM (headquarter in Beijing. 19F, West Tower, Twin Towers,B-12 Jianguomenwai Avenue, Chaoyang District, Beijing, P.R. China) is the data controller for processing your personal data.

How we collect personal data?
We collect personal data when:
Personal data that you provide to us when you purchase a product or service;
Personal data which you provide as part of correspondence, feedback, help and dispute settlement. 
Personal data which you provide when you request software downloads;
Personal data which you provide when you creating a user account (login user name and password) and other information which you enter or provide through the use of our websites.
you request information or materials (e.g., whitepapers or Product cases);
Personal data which you provide when you participate in our surveys, evaluations or during our promotions activities, Marketing Campaigns.
Personal data which you provide when you apply for a job or submit your resume;
Personal data which we collect when you use our website through cookies
Personal data we receive from external parties:
Our commercial partners and/or third-party service providers may provide personal data to us. If so, we will require these partners and service providers to ensure compliance with the relevant applicable legal requirements and that they have explicitly informed the personal data subject and obtained the authorizations and / or express consents from the personal data subjects.

What personal data we will collect
The types of personal data we will collect include:
Your first and last name;
Your job title and your company's name; 
Your office location, mail or billing address, or other physical address for onsite services. (including street name, name of a city or town, state/province, postal code);
Your e-mail address;
Your telephone number;
Your educational background, qualifications, employment experience, and job interest (All for job applicants only);
Any other identifier that permits CHINA ENTERCOM to make physical or online contact with you;
Any information that we collect from you about your online accounts, such as usernames and passwords;
Your marketing preferences, including any consents you have given us;
Any other information that you provide to us
We also collect information on our website via cookies. Please refer to the "Cookie Policy": for more details.

For what purpose and on legal basis, we process your personal data?
We handle your personal information in accordance with the principles of legality, legitimacy, necessity and integrity. According to the <Personal information protection law of the people's Republic of China>, the following legal basis are allowed for processing personal information:
(a)Consent has been obtained from you before processing;
(b)Processing is necessary for the conclusion and performance of the contract to which the individual is a party, or for the implementation of human resources management in accordance with the labor rules and regulations formulated according to law and the collective contract signed according to law;
(c)Processing is necessary to perform its statutory duties or obligations;
(d)Processing is necessary to deal with public health emergencies, or to protect the life, health and property safety of natural persons in emergencies;
(e)In public interests to perform news reports and public opinions supervision, it is allowed to handle personal information within a reasonable scope;
(f)To handle personal data disclosed by individuals or otherwise legally disclosed within a reasonable scope in accordance with the provisions of this Law;
(g)Other circumstances as stipulated by laws and administrative regulations;
When choose to use the CHINA ENTERCOM products and services, it is deemed as you agree with what we describe in this policy. Whilst, it is certainly our obligation to ask for your prior separate consent when using your information for purposes not covered by this Privacy Policy.
If you or the companies you on behalf of are going to establish a contractual relationship with CHINA ENTERCOM, it is necessary for us to collect your personal information to conclude and perform the contract, and if you choose to submit the resume online to us, it is deemed as you agree to let us to process your personal data to conduct the recruitment.
In addition, Other specific usage scenarios of your personal information are as follows:
The use of personal information may include verifying your identity, receiving and paying money, communicating with you, providing customer service and arranging delivery
Using personal data to provide the services you request and respond to comments or complaints that you may send to us;
In order to improve our products and services, and carry out internal audit, data analysis and research, marketing analysis, we will monitor users' use of our products and services, and may use your personal information to help monitor, improve and protect our products, content, services and websites.
May customize products or services to you with personal data provided by you.
Your personal data may be used to facilitate the network and information security, including preventing unauthorized access to electronic communication systems and timely preventing infringement of computer and electronic communication systems;
To comply with applicable laws and protect our legal business interests and statutory rights, including, but not limited to, the use for legal claims, compliance, regulatory, investigative purposes (including disclosure of such information related to legal procedures or litigation).
In addition, with your consent, we will send you your requested materials about our products and services, or other products and services from us and our affiliates, our carefully selected partners that we think you maybe interest in. You may withdraw your consent at any time (Click "Unsubscribe").
How do we share, transfer, and publicly disclose your personal information?
5.1. Sharing 
We will not share your personal information with any company, organization or individual other than CHINA ENTERCOM, except for the following cases:

If necessary to perform a service you request from us, to execute an order you have placed or to follow-up on your enquiries, we will share your information with other CHINA ENTERCOM entities or third party service providers, for example email and hosting providers and the like.
We (or any third party on our behalf) disclose or transfer personal data to others as follows:
(a) to service providers that provide hosting services and technology service providers, business process outsourcing service providers and call centre service providers;
(b) as required in order to establish, exercise or defend or to protect legal claims, including in relation to our contracts with our clients and in order to protect the rights, property or safety of us, our business, any affiliate, our customers or others, including to legal advisors, government and law enforcement authorities and with other parties involved in, or contemplating, legal proceedings;
(c) to competent regulatory, prosecuting, tax or governmental authorities, courts or other tribunals in any jurisdiction or markets, domestic or foreign, upon their request or in accordance with or as desirable in respect of any applicable Law;
(d) to any other third parties to the extent such disclosure is required under applicable law or to enable products and services to be provided to you and/or our customers;
(e) payment infrastructure providers and persons from whom we receive or to whom we make payments on your or our customer's behalf;
(f) to prospective sellers or buyers as part of a sale or merger of our or any affiliates business or assets (subject to local laws).

If a third-party service provider processes your information on behalf of CHINA ENTERCOM for the above purposes, when they share your information, we ensure that they take appropriate protective measures to protect your information, and we will only share the necessary personal information. Subject to the purpose stated in this policy, if we share your sensitive personal information or a third-party company changes the purpose of using and processing your personal information, we must ensure your prior authorization and consent are obtained.

5.2. Transfer
We will not transfer your personal data to any company, organization or individual other than CHINA ENTERCOM and its affiliates, except:

a). Already obtained your prior express authorization or consent;
b). To meet the requirements of laws, regulations, legal procedures, or mandatory government requirements or judicial rulings;
c) If we or our affiliates are involved in a merger, division, liquidation, acquisition or sale of assets or business and your personal information may be transferred as part of such transaction, we will ensure the confidentiality of the information upon transfer and require that a new company or organization holding your personal information continue to be subject to this privacy policy, otherwise we will require the company or organization to renew your consent.

5.3. Public disclosure
We will publicly disclose your personal information only if:
a) Get your express consent;
b) Under the mandatory requirements of regulations, legal procedures, litigation or government departments.

5.4. Exceptions to prior consent for sharing, transfer and public disclosure of personal information
(a) Direct related to national security and national defense security;
(b) Is directly related to public safety, public health, and major public interests;
(c) Is directly related to the criminal investigation, prosecution, trial and execution of the judgment;
(d) To protect the major legitimate rights and interests of your life or other individuals, but it is difficult to obtain personal consent;
(e) The personal information that you will disclose to the public by yourself;
(f) Collecting personal information from the legally publicly disclosed information, such as legal news reports, government information disclosure and other channels;
(g) It is necessary to sign and perform the contract according to the requirements of the personal information subject;
(h) Is necessary to maintain the safe and stable operation of the product or service provided, such as the discovery and disposal of faults of the product or service;
(i) Other circumstances as stipulated by laws and regulations.

According to the law, sharing, transfer of personal information that has been de-identified, and ensure that the data receiver cannot recover and re-identify the personal data subject, does not belong to the external sharing, transfer and public disclosure of personal data, and the preservation and processing of such data do not need further notice to you or your consent.

Store of personal data
We store your personal information reasonably and legally in accordance with the law.

Your personal information is stored in the people's Republic of China. If some products or services involve cross-border, we need to transmit your personal information abroad. We will implement it in strict accordance with the provisions of the law and ensure the security of your personal information.
  
If the processing purpose is met, your personal information will be deleted unless we have the legal right or obligation to continue to retain the information. For example, if you are a customer of CHINA ENTERCOM, we will save your data during the duration of your contractual relationship with us; To the extent permitted by the policy, if we need to perform the necessary purposes described in this policy, we will continue to retain your information after the end of the contractual relationship. The retention period depends on legal and contractual requirements, the nature of the relationship between the parties, the nature of the data involved and technical necessity. The law may require us to retain certain information for a specific period of time. If we save personal data after obtaining your consent and authorization for marketing purposes, we will continue to process it before you request to cancel the authorization: and we will process your personal data for a certain period of time after that in order to implement your request. We will also keep a record of your request that we do not send you direct marketing materials or process your data, so as to respect your request in the future.。

7. How do we protect your data

(1) We will adopt the most mature security technologies to collect, use, store and transmit user information in accordance with security standards and principles, and inform you of the purpose and scope of use of relevant information through user agreement and privacy policy;

(2) We value information security very much. We have established a dedicated information security team. We will review the security background of the person in charge of security management and personnel in key security positions. We have established a complete information security management system and internal security incident handling mechanism. We will take reasonable and feasible security measures and technical means in line with industry standards to store and protect your personal information from loss or unauthorized access, public disclosure, use, tampering, damage, or disclosure. We will use encryption technology to ensure the confidentiality of data. We will use trusted protection mechanisms to prevent malicious attacks on data; At present, this website and our important external information system have passed the level 3 evaluation of China MLPS.

(3) We will carry out data security awareness training and security awareness training and assessment for employees to strengthen their understanding of the importance of protecting personal information. We will deploy access control mechanism. We will carry out identity authentication and authority control for employees handling personal information, and sign confidentiality agreements with employees and partners who have access to your personal information to clarify job responsibilities and behavior standards Then, ensure that only authorized personnel can access personal information. Any violation of the confidentiality agreement will be punished internally or investigated for relevant legal responsibilities (including termination of contract, dismissal and criminal proceedings)

8. Rights you can exercise over your personal information

According to the law, you have the right to ask us:
(1) Allow you to access, query, and obtain copies of your personal information saved by us;

(2) Provide you with a copy of the personal information you authorize to us or send a copy of the information to a third party in a common machine-readable format;

(3) Update or modify your personal information to make it accurate;

(4) Delete your personal information from the storage record or cancel your account;

(5) Restrict the processing of your personal data or raise objections to your data processing;

(6) Post constraint to system automatic decision making.

In some business functions, we may only make decisions based on non manual automatic decision-making mechanisms including algorithms. If these decisions affect your legitimate rights and interests, you can contact us through the contact information at the end of this policy.
(7) If our processing of your personal information is based on your consent authorization, you can revoke your consent authorization. However, this does not affect our processing of your personal information before you canceling the consent authorization.

If you want to stop receiving the company's publicity and marketing information, you can send email to  enquiry@china -entercom. net, marketing@china –entercom.net, or browse this website for unsubscribe page and select relevant unsubscribe options.


9. Our response to your above request:

To ensure security, you need to provide a written request or prove your identity in other ways. We may ask you to verify your identity before processing your request.

In principle, we will not charge for your reasonable request, but we will charge a certain cost for repeated requests that exceed the reasonable limit according to the situation.

We may refuse requests that are unreasonably repeated, require too many technical means (for example, need to develop new systems or fundamentally change the current operation), pose risks to their legitimate rights and interests, or are very impractical.

Under the following circumstances, we will not be able to respond to your above request in accordance with laws and regulations:

(1) Directly related to national security and national defense security;

(2) Directly related to public safety, public health and major public interests;

(3) Directly related to criminal investigation, prosecution, trial and execution of judgment;

(4) We have sufficient evidence to show that you have subjective malice or abuse of rights;

(5) Responding to the request of the personal information subject will cause serious damage to the legitimate rights and interests of you or other individuals and organizations;
(6) Involving trade secrets.

10. Other website links and social media portals
This website may include links to other websites. This privacy policy does not apply to external links or external websites, and we are not responsible for the privacy protection content of these external links or websites. This privacy policy does not cover the processing of personal information by companies or websites other than CHINA ENTERCOM or its affiliates. We encourage you to review the privacy policies of other companies or websites before submitting your personal information.

This website uses the following social media portals: weibo, wechat and Tencent video, which can be identified by social media logos. You can click the social media logo button to jump to social media when browsing this website. These social media providers will not directly collect your personal data when you browse this website. Your personal data will not be transferred until you click the social media button. After clicking the social media button, your traffic will be automatically transferred to the corresponding social media providers.
11.Cookies

Cookie and similar device information identification technology are widely used in the Internet. When you use our services, we may use relevant technologies to send one or more cookies or anonymous identifiers (hereinafter referred to as "cookies") to your device to collect, identify and store information when you visit and use this website. We use cookies to count page access and frequently used functions. This can help us continuously improve our website to meet the needs of visitors. We use cookies to personalize content and promotion, and analyze social media functions and website traffic. This will share information about your use of the website with social media, advertisers and data analysis partners. Most browsers provide users with the function of clearing browser cache data. You can clear the data accordingly, or modify the acceptance of cookies or reject our cookies. You may not be able to use cookie dependent services or corresponding functions because of these modifications.

For more information about cookies, please click [cookie policy] to view.

.
12 Tencent Cloud Analytics
Our website uses Tencent Cloud Analytics, which is a web analytics service provided by the third party provider Tencent, Inc. (“Tencent”). Tencent Cloud Analytics is used for the purpose of evaluating your use of our website, compiling reports on website activity and other services relating to website activity and internet usage. The information generated by the cookie about your use of the website is usually transmitted to and stored by Tencent on servers in China. This transfer is covered by Tencent’s Privacy Policy and a separate data processing agreement that we have concluded with Tencent.

13. Protection of minors

The products and services currently provided by CHINA ENTERCOM are not for minors and we will not actively collect information about minors.

In e-commerce activities, we presume that you have corresponding civil capacity. If you are a minor, we urge you to ask your parents or other guardians to read this policy carefully and browse this website with the consent of your parents or other guardians. If you have any questions, please contact us at the end of this policy.

14 Policy Updates

CHINA ENTERCOM promises to collect and use your personal information reasonably and legally in accordance with laws and regulations. We will regularly review this privacy policy to ensure that its content is accurate and clearly visible on this website. We undertake to regularly review the revised privacy policy to ensure its compliance with the law. If there is a major revision to this privacy policy, we will post a prompt on the website and attach an updated version of the privacy policy.

15.Contact Us

CHINA ENTERCOM is subordinate to CITIC International Telecommunications (Information Technology) Co., Ltd.
CITIC International Telecommunications (Information Technology) Co., Ltd. has appointed Bird & Bird DPO services SRL as our data protection officer. For question about the privacy protection of the company, you can send emails to DPO CITICTelecom-CPC @twobirds. com.
If you have any questions about this privacy policy or other matters, please send emails to gdpr@china-entercom.net or enquiry@china-entercom.net.
You can also mail your questions to the following address:
19F, West Tower ,Twin Towers,B-12 Jianguomenwai Avenue, Chaoyang District, Beijing, P.R. China
Postal Code: 100004
We will review and verify your requests, and will reply to you within 15 working days.

This version was last updated on December 18, 2021

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