Legal Notice

General Privacy Policy

Privacy Policy, effective date: March 13, 2019, last updated date: June 19, 2020

Your privacy is important to us and we, in Shiji Group believe that privacy is good for business. We are therefore committed to protecting your Personal Data, collected both through our Website and for a range of business purposes in connection to provision of our products and services (collectively the “Services”).

Introduction

This Privacy Policy (the “Policy”) constitutes the Privacy Notice and applies when you visit a Shiji Group owned or operated websites or use any Shiji Portal made available to the users.

A reference to “Shiji”, “we”, “us” or “our” is a reference to Shiji (Hong Kong) Limited and its relevant affiliates involved in the collection, use, sharing, or other processing of Personal Data. You can find our address and our affiliates here: https://www.shijigroup.com/worldwide-directory

Please note that depending on which Shiji Group entity you contract with to provide Services, the following entities may be a data controllers responsible for processing your Personal Data: https://www.shijigroup.com/worldwide-directory

The Shiji Group owns and operates several websites (the “Shiji Group Websites”):

https://www.shijigroup.com

https://support-intl.shijigroup.com/portal/shijigroupintl

https://support-intl-ac.shijigroup.com/portal/en/signin

https://support-intl-concept.shijigroup.com/portal/en/signin

https://www.mycheck.io

https://docs.shijigroup.com

https://www.stayntouch.com

https://www.snapshot.travel

https://hetras.shijigroup.com

https://web.iceportal.com

https://www.reviewpro.com

https://concept.shijigroup.com

https://infrasys.shijigroup.com

This Privacy Policy aims to inform you about how we collect, use, disclose and store information about you when you:

- Interact or use Shiji Group Websites, for example when you request a demo or request information about our Services including via the Contact forms and a telephone enquiry service,

- Register and/or attend any of our events, webinars, or the conferences we attend (collectively “Events”),

- Requesting any Marketing information, for example when you subscribe to our Newsletter, and

- If you use any of Shiji Services, for example when you are a user to Shiji Services and submit a ticket to Shiji Support Centers, or if you decide to call our Support Center.

What information does Shiji collect?

Information You Provide to Us

From Websites or Events: When you use Shiji Group Websites, we collect Personal Data you provide directly to us when you make contact with us, for example, on our “Request a demo” (or similar) online form, if you send as a query via the Contact form or if you register for our webinar. The type of data we collect directly from you includes: name, email address, country, phone number, company, property name, as well as any additional information you choose to include in the Contact form.

From Services: When you use Shiji products and services we receive and store data provided directly to us. For example, when setting up new users, or log-in to the any Shiji Portal, we collect Personal Data such us: name, e-mail address, phone number.

Information We Collect Automatically

Cookies are used on some pages of our Website. Even if you do not contact us via our online Contact form or e-mail, we automatically collect certain information about your use of the Website.

Different types of cookies that we collect

A cookie that we collect can be classified by its lifespan and the domain to which it belongs. By lifespan, a cookie is either a:

· session cookie which is erased when the user closes the browser or

· persistent cookie which remains on the user's computer/device for a pre-defined period of time.

As for the domain to which it belongs, there are either:

· first-party cookies are cookies set by Shiji Group;

third-party cookies are cookies that another party places on your device thorough our Services. Third-party cookies may also be placed on your device by our business partners so that they can use them to advertise products and services to you elsewhere on the Internet.

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Cookie OPT-OUT (Deleting Cookies):

You may control the use of cookies at the browser level. You can deactivate the use of cookies in the settings of your browser at any time. To find out how to change the settings, please consult the help function of your browser. However, we want to make you aware that if you choose to disable cookies, it may limit your use of certain features or functions on the Website.

Data Analytics and Targeting

We also employ third party companies, such as Google Analytics, and individuals to facilitate our Website, to assist us in analyzing how our Website is used by the Users. We and third parties may use cookies, pixels and other technologies that automatically collect information about you.

We may also work with third parties to serve ads to you as part of a customized campaign on other websites. These third parties may also collect personal information about your online activities over time and across different websites when you use our website to help predict your preferences and to display (and to enable other third parties to display) ads to be more likely to be of interest to you. These services track information about Users including IP address, browser type, referring and visited pages as well as time spent on actual pages. We note however, that the IP address transmitted from your browser, as part of Google Analytics will not be merged with other data from Google. To learn more how Google may use information collected through our Website, click here.

Some third-party service providers that we engage (including third-party advertisers) may also place their own cookies on your browser. If you wish to opt out of interest-based advertising, click here. Note that this Privacy Policy covers only our use of cookies and does not include use of cookies by such third parties.

Google Analytics OPT-OUT:

For more information on how to opt out of data collection through Google Analytics you may want to visit the Google Analytics Opt-out Browser Add-on, click here.

How We Use Your Information

Websites or Events:

How do we use your Personal Data will depend on how you use our Website, the choice you make in your settings and your other decisions (for example if you decide to subscribe to the Newsletter). We will use the data we collect via Shiji Websites:

- To improve our Websites to personalize our visitor’s experience on the Websites;

- To respond to Contact form requests or e-mails;

- To provide you with information that we believe may be useful to you, such as information about products or services we offer, including when you subscribe to the Newsletter, request a demo, or to provide you with access to one of our webinars;

- To comply with applicable laws, regulations, or legal process as well as industry standards and our company policies;

- To prevent fraud or other misuse, as part of our efforts to keep our Website secure; and

- To monitor and analyze trends, usage, and activities of visitors to the Sites.

Our use of your Personal Data may be based on our legitimate interest (e.g. to ensure network and information security or to provide a demo following your request), and for the direct marketing purposes, or on the basis of the consent you provide (e.g. when you submit to the Newsletter).

Services:

We may use the information we collect from our customers and their users in connection with the Services we provide, including to:

- Perform our obligations in accordance with any contract that we may have with you;

- Provide you with a user account in Shiji Portal;

- Provide a Customer Support and respond to submitted enquiries, including by telephone when your conversation may be recorded;

- Process and complete transactions, and send relate information including the invoices;

- Investigate and prevent fraudulent activities, unauthorized access to the Service and other illegal actions; and

- For any other purposes which we notify the customers and users.

We may use your Personal Data in this context based on the contract that we have in place with the customer or our legitimate interest (e.g. the prevention of fraudulent activities). In particular, when you contact Shiji Customer Support your telephone conversation are recorded to monitor the quality of the telephone conversations, where we have a legitimate interest in recording telephone conversations, because the recordings enable Shiji to improve its service, while the infringement on the customer privacy is limited.

How We Share Information to Third Parties

Service Providers:

We may share your Personal Data with third party vendors, consultants and other service providers who we employ to perform tasks on our behalf. These companies include (for example) help desk software providers (ZOHO CRM) and the cloud computing service provider (AWS).

Shiji Group companies:

We may share your Personal Data with our parent company, subsidiaries and/or Shiji affiliates for the purposes consistent with this Privacy Policy.

Disclosures required by law:

Under certain circumstances, we may be required to disclose Personal Data in response to valid request by the authorities.

Security

It is really important to us that your information is safe, whether it is information you provide to us or whether it is the information we collect it automatically. We use a secure, encrypted connection (using a TLS protocol) on all Shiji Group Websites where Personal Data is transmitted. We have also installed technical and organizational measures in order to safeguard Shiji Group Websites against loss, theft, misuse, destruction, access, changes or the distribution of your data by unauthorized parties. Although we use reasonable efforts to help

protect your information, transmission via the Internet is not completely secure, and we cannot guarantee the confidentiality of information transmitted to us over the Internet.

Retention

The Personal Data that you submit to us will only be retained as long as required for the purpose for which it was collected or as required to do so by law.

California Privacy Rights

This section provides additional details about the Personal Data we collect about California consumers and the rights afforded to them under the California Consumer Privacy Act (the “CCPA”).

For more information about the Personal Information (as such the term is defined in the CCPA) that we have collected over the last 12 months, please see the Data we collect through this Website section above. We collect this information for the business and commercial purposes described in the How We Use Your Information section above. We share this information within Shiji Group described in the How We Share Your Information section above. Please note that Shiji use third-party cookies for our advertising purposes as described in Third party cookies section above. Shiji does not sell (as such term is defined in the CCPA) the personal information we collect.

Whereas with certain limitations, the CCPA provides California consumers the right to request to know more details about the personal information that is being collected (including how we use and disclose this information), to delete their personal information, to opt out of any “sales” that may be occurring, and not to be discriminated against for exercising these rights.

Please note that we may ask you to validate your California residency before responding and acting upon such request. California consumers may make a request pursuant to their rights under the CCPA by contacting us at dpo@shijigroup.com

Updates to our Privacy Policy

We reserve the right to modify this Policy at any time. If we make material changes to this Policy, we may notify you on our Website, by a blog post, by email (if available), or by any method we determine. The m

"Last Updated" date at the beginning of this Privacy Policy. Any changes we make to our Privacy Policy are effective as of this Last Updated date and replace any prior Privacy Policies.

How to contact us

If you have any questions or concerns about this Privacy Policy or want to exercise your right set out in this Privacy Policy, please contact us by: - Sending us e-mail to: dpo@shijigroup.com; or

- Sending us mail at (please see Data Protection Officer details below)