CLPS Incorporation
Personal Information Privacy Policy
(Effective: July 2022)
This Personal Information Privacy Policy ("Policy") applies to the processing of your personal information in connection with activities conducted by companies directly or indirectly controlled by CLPS Incorporation ("CLPS"). CLPS understands the importance of your personal information and is committed to protecting its security to the fullest extent possible. We strive to maintain your trust by adhering to the following core principles of data protection: accountability, purpose specification, informed consent, data minimization, security assurance, subject participation, and transparency. Furthermore, CLPS is committed to implementing industry-standard security measures to safeguard your personal information.
Please read and understand this Policy carefully before providing us with your personal information or using our products and services. This Policy explains:
I. Purposes of Processing Your Personal Information
II. Methods of Processing Your Personal Information
III. How We Protect Your Personal Information
V. How We Handle Children's Personal Information
VI. Global Transfers of Personal Information
I. Purposes of Processing Your Personal Information
1. When you apply for employment, make job-related inquiries, participate in training, complete onboarding procedures, or use our mini-programs, applications, or other products and services across various platforms, our ability to process your applications or provide these services depends on the personal information you submit. In such cases, the primary purpose of processing your data is to complete these requested tasks and services.
2. We may also process your personal information to enter into or perform a contract to which you are a party, to implement human resource management in accordance with lawfully established labor rules and regulations, or to fulfill statutory duties and legal obligations.
II. Methods of Processing Your Personal Information
1. Information Collection
During your interactions with us—such as applying for positions, engaging in training, onboarding, or using our digital platforms—you may voluntarily provide (or authorize us to collect) categories of personal information both online and offline, including: name, date of birth, gender, educational background, degree, occupation, and work experience. This encompasses basic personal details, educational history, and professional background. Additionally, you acknowledge that we may collect personal information you have made public yourself, or that has otherwise been lawfully disclosed, to fulfill our processing purposes.
2. Information Storage and Management
a)If collected via online platforms, we may store your information on those platforms and strictly safeguard our corporate account credentials and passwords.
b)Paper documents containing personal information are securely stored within our office premises under restricted access.
c)Information stored on our internal computers or network servers is protected by properly maintained credentials and passwords.
d)We may perform routine data administration, which includes editing (modifying, deleting, or appending) your personal information, as well as classifying and compiling aggregate data sets.
3. Transfer, Sharing, and Disclosure
a)You understand and agree that, to achieve our processing objectives, we may share your personal information via email or other secure methods as follows:
•Transferring and sharing your information internally among CLPS entities.
•Sharing information with our clients, provided we confirm beforehand that the recipient is a contracted business partner and that we are contractually obligated to provide such data.
•Sharing information with our suppliers, provided we verify an active contract containing stringent personal information protection clauses that dictate the purpose, duration, methodology, data types, and security measures required of the supplier.
b)We will not publicly disclose any of your personal information, except as explicitly requested by you or as strictly required by judicial authorities or government agencies.
4. Data Deletion
If you request the deletion of your personal information, withdraw your consent for processing, or explicitly object to our processing of data you have made public, we will promptly verify the circumstances and delete the relevant information.
5. Third-Party Processing
When utilizing third-party companies, organizations, or individuals to process personal information on our behalf, we execute strict confidentiality agreements. These agreements mandate that third parties process the data solely in accordance with our instructions, this Policy, and all applicable security regulations.
6. Explicit Consent
If processing activities fall outside the scope of what is necessary for contract performance, legal human resource management, or other legally exempt circumstances, and if applicable law expressly requires it, we will obtain your separate, explicit consent before processing your personal information.
III. How We Protect Your Personal Information
1. We implement rigorous classification protocols for personal information stored in our internal systems. This classification is based on the data's sensitivity and privacy level. We enforce strict role-based access controls, ensuring internal personnel can only access specific data categories necessary for their authorized work duties.
2. We have deployed industry-standard security measures to protect your data against unauthorized access, public disclosure, use, modification, damage, or loss. We are committed to taking all reasonably practicable steps to secure your personal information.
3. We strictly limit data collection to what is relevant and necessary. We will only retain your personal information for the period required to fulfill the purposes outlined in this Policy, unless a longer retention period is mandated or permitted by applicable law.
4. While no internet environment is entirely secure, we will do our utmost to guarantee the safety of the information you transmit to us. In the unfortunate event of a physical, technical, or managerial security breach leading to unauthorized access, tampering, or data loss, we will promptly notify you in accordance with relevant laws. This notification will include: the nature and potential impact of the incident, our remedial actions, recommended risk mitigation steps for you, and available remedies. We will notify you via email, letter, phone call, or push notification. If individual notification is impractical, we will issue a public announcement in a reasonable and effective manner. We will also report the incident and our response to the appropriate regulatory authorities as required.
IV. Your Rights
1. Access and Copy Your Information
For personal information generated during your use of our services, or data you can no longer access, we will provide you with access or copies upon request, provided the request does not require disproportionate effort.
2. Correct and Update Your Information
If you discover errors or omissions in the personal information we hold about you, you have the right to request corrections or updates.
3. Delete Your Information
You may request the deletion of your personal information if:
a)Our processing violates applicable laws or regulations;
b)We processed your information without your consent;
c)You withdraw your consent;
d)Our processing breaches our agreement with you;
e)You cease using our products or services; or
f)We discontinue providing products or services to you.
If we grant your deletion request, we will concurrently instruct any third-party entities that received your data from us to delete it promptly, unless legal exceptions apply or they possess independent authorization. When you delete information from our active systems, we may not instantly remove it from backup systems, but it will be securely deleted during the next scheduled backup update.
4. Withdraw or Modify Consent
We require specific personal information to process job applications and provide related services. If you withdraw or reduce the scope of your consent, we will cease processing the affected data, which may result in our inability to proceed with your application or provide specific services. However, your withdrawal of consent will not retroactively invalidate the legality of processing conducted prior to your request.
5. Responding to Your Requests
a)To exercise any of the rights above, please reach out using the details in Section VIII. For security purposes, we may require a written request or identity verification before processing your inquiry. We aim to respond within 30 days. If practical circumstances necessitate an extension, we will notify you in advance with an explanation.
b)We do not charge fees for reasonable requests. However, for repetitive requests or those exceeding reasonable limits, we may charge a cost-recovery fee. We reserve the right to refuse requests that are unfounded, abusive, require disproportionate technical effort, jeopardize the rights of others, or are practically unfeasible.
c)We may be unable to fulfill your request if it:
•Conflicts with our legal or regulatory compliance obligations;
•Relates directly to national security or defense;
•Relates directly to public safety, public health, or significant public interests;
•Relates directly to criminal investigations, prosecutions, or the execution of judgments;
•Involves subjective malice or an abuse of rights on your part;
•Conflicts with the protection of vital interests (e.g., life or property) where obtaining consent is impossible;
•Would cause serious harm to your legitimate rights or those of a third party; or
•Involves proprietary trade secrets.
V. How We Handle Children's Personal Information
1.Before applying for positions, making inquiries, participating in training, onboarding, or using our digital platforms, you must ensure you are at least 16 years of age. If you are under 16, please do not submit applications or use our services, as we are unable to process them.
2.In situations where a child's personal information is collected, it will only be processed with explicit, verifiable consent from a parent or guardian, to the extent permitted by law, or as necessary to protect the child. We define a "child" as any individual under the age of 14.
3.If we discover that we have inadvertently collected personal information from a child without verifiable parental consent, we will take immediate steps to delete the data.
VI. Global Transfers of Personal Information
Generally, personal information collected and generated within the People's Republic of China (PRC) is stored within the PRC. Because our clients operate globally, we may deliver products or services utilizing global resources and servers. This means that, subject to your explicit authorization and consent, your personal information may be transferred to or accessed from overseas jurisdictions.
These jurisdictions may possess differing data protection laws or lack such laws entirely. In these instances, we will fully comply with the prevailing laws, regulations, and rules of the PRC. We will execute necessary security assessments, obtain personal information protection certifications, formalize strict contracts with overseas recipients, conduct data protection impact assessments, and implement all requisite measures to ensure your personal information receives a level of protection equivalent to that mandated within the PRC.
VII. Policy Updates
This Policy may be amended periodically to reflect the promulgation, revision, or repeal of national laws and regulations. We will post any modifications to this Policy on this website. For material changes, we will provide a prominent notice to ensure you are fully informed.
VIII. Contact Information
If you have any questions, comments, or concerns regarding this Policy, please contact us at:
•Phone: +86-21-3126-8010
•Email: pip@clpsglobal.com
We generally respond to all inquiries within 30 days. If an extension is required due to the complexity of the request, we will notify you in advance and provide an explanation for the delay.