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Privacy Policy

2021-10-31

1. Purpose

Protecting the privacy of individuals on the Internet is critical to the future of Internet business and the realization of a true Internet economy. PSS Software Systems (PSS) takes privacy of individuals seriously. This privacy policy has been written to demonstrate our strong commitment to the protection of personal data and privacy. This privacy policy outlines how we process such information that directly or indirectly identifies an individual (hereinafter "personal data").


2. Scope

This privacy policy applies to Personal Data that you provide to Platinum Software Systems (PSS) or that is derived from Personal Data as described below.


3. General information


3.1 Data Controllers

The data controller of the HRM products, HRM services and Internal IT systems is Platinum Software Systems whose office is located at Floor 1-2, Building 10, No. 99 Tianzhou Road, Caohejing Development Zone, Shanghai, China (hereinafter referred to as "PSS"). You can contact us by phone at 021-64952200 or by email at data.privacy@platinumchina.com.


If a registration form is made available on PSS website, the data controller may change, depending on the actual data provided or the purpose for which the data was collected, but in any case, the data controller will be indicated in the privacy statement of the individual registration form.


3.2 How does PSS process my personal data?

PSS will only process the personal data provided in accordance with this privacy policy. See section 4 below for details. Where the processing of personal data is permitted by law, you can find information on the type or purpose of the personal data processed by PSS in section 4 below.


3.3 Duration of the processing of personal data

Where PSS uses your personal data as permitted by law (see section 4 below), PSS will store your personal data until (i) the purposes described below have been fulfilled, or (ii) you object to PSS's use of your personal data (where PSS has a legitimate interest to use your personal data). (iii) you withdraw your consent (you have previously consented to PSS's use of your personal data). However, if PSS is required by law to retain your personal data for a longer period of time, or if PSS needs your personal data to defend its interests or legal defenses, PSS will retain your personal data until the end of the relevant retention period or until the relevant dispute is resolved.


3.4 Why do I need to provide personal data?

In general, the granting of your consent and the provision of any personal data is entirely voluntary; if you choose not to give your consent or provide your personal data, this will generally not have any adverse effect on you.


However, there are circumstances in which PSS is unable to take action if it does not have access to your specific personal data, for example, where your personal data is required to process your business processes, in which case PSS will not be able to comply with your request without the relevant personal data.


3.5 Where will my personal data be processed?

there are 2 ways of deploying PSS's application server, a private deployment (deployed on the customer's server) and a hosted deployment in the cloud (Aliyun servers). When the customer chooses to deploy on their own server, the user's data is stored directly on their server and PSS only provides the processors and does not collect the personal data; when the customer chooses to deploy in the cloud, PSS stores the user's personal data.


3.6 Rights of Data Subjects

You may at any time request from PSS information about personal data processed by PSS relating to you, as well as the correction or deletion of any such personal data. Please note, however, that PSS may delete your personal data, provided that PSS has no legal obligation or legitimate interest to retain such data. Please also note that if you request PSS to delete your personal data, you will no longer be able to use any PSS services that require PSS to use your personal data.


If PSS uses your personal data with your consent or to perform a contract with you, you may further request PSS to provide you with a copy of the personal data that you have already provided to PSS. PSS will consider your request carefully and will discuss with you how to satisfactorily fulfill your request.


In addition, you may request PSS to block any further processing of your personal data if (i) you indicate that the personal data PSS holds about you is incorrect (only if PSS requests verification of the accuracy of the personal data in question); (ii) PSS's processing of your personal data is inaccurate; or (iii) PSS's processing of your personal data is inaccurate. there is no legal basis for the processing and you request PSS to prevent further processing of your personal data; or (iii) PSS no longer needs your personal data, but you claim to require PSS to retain such data in order to institute or exercise legal rights or to defend third party proceedings, or (iv) you object to PSS processes your personal data (on the basis of PSS's legitimate interests as detailed in section 4 below), subject to a review of whether PSS has a legitimate interest or statutory obligation to process your personal data. Please send any requests directly to data.privacy@platinumchina.com


3.7 Right to Complaint

If you believe that PSS has not processed your personal data in accordance with the requirements of this Statement or applicable EEA data protection law, you may, at any time, lodge a complaint with the data protection authority of the EEA country in which you reside or in which PSS's registered office is located.


3.8 Links to other websites

PSS site may contain links to other (i.e., non-PSS Group company) web sites. PSS is not responsible for the privacy practices or the content of websites other than those of the PSS Group companies. We therefore recommend that you carefully read the privacy statements of such external websites.


4. How does PSS use my personal data as required by law?

In the following cases, PSS may process your personal data in accordance with applicable data protection laws.


4.1 To provide the requested product or service

If you order products or services from PSS, PSS will use the personal data you enter in the registration form (typically your name, (e-mail) address, telephone number, company name and address, job title and role, as well as the credit card number or bank details involved in the payment to PSS) solely for the purpose of the service. This may include taking the necessary steps before entering into a contract, responding to your relevant queries, providing you with shipping and billing information, and processing or providing customer feedback and support. This may also include conversational data generated by your use of the chat feature of this website or other local PSS websites, contact forms, emails or phone calls. For the purposes of this Privacy Statement, "products and services" includes access to PSS's website services, products, contests, prizes, other content, non-marketing related news, white papers, courses, training and events.


4.2 Ensuring Compliance

PSS and its products technologies and services are subject to the export laws of various countries, including, but not limited to, the European Union and its member states and the United States. You acknowledge that, in accordance with applicable export laws, trade sanctions and embargo laws enacted by such countries, PSS must take appropriate measures to prevent entities, organizations and related parties on government-published lists of sanctioned parties from accessing certain products, technology and services through PSS's website or other delivery channels controlled by PSS. This may include (i) automatically checking any user registration data and other information provided by users relating to their identity as described in this Statement against the relevant Sanctioned Parties List; (ii) repeating such checks periodically when the Sanctioned Parties List is updated or when users update their personal information; (iii) blocking access to information that may be consistent with the Sanctioned Parties List when such information is found; and (iv) preventing access to information that may be consistent with the Sanctioned Parties List. access to PSS services and systems; and (iv) contacting users to confirm their identity in the event that information is discovered that may match the list of sanctioned parties. In addition, you acknowledge that, in order to ensure compliance, any information necessary to track your choices regarding the processing or use of personal data or the receipt of marketing materials may be stored and exchanged between members of the PSS Group (i.e., whether or not you have expressly consented to receive or opted out of receiving marketing materials, as required by the country/region in which the relevant PSS Group company operates).


4.3 Legitimate interests of PSS

Each of the following use cases constitutes a legitimate interest of PSS to process or use your personal data. If you do not agree with this approach, you may object to the processing or use of your personal data by PSS as described below.


4.3.1 Questionnaires

PSS may invite you to participate in questionnaires. In general, you are not required to provide any personal data to answer these surveys. However, if you enter personal data in surveys, PSS will use such personal data to improve its products and services.


4.3.2 Creation of anonymous data sets

PSS will anonymize the personal data provided in accordance with this privacy statement to create anonymous data sets that will subsequently be used to improve the products and services of PSS and its affiliated companies.


4.3.3 Phone calls and chats are recorded to improve the quality of the service

When making a phone call or chat, PSS records such calls (you are usually informed that you want to be recorded during the call or before the recording begins) or chats in order to improve the quality of PSS's services.


4.3.4 Make sure you are always up to date with the latest information/requests for feedback

Given your existing employment relationship or business relationship with PSS, PSS may provide you with information about its products or services (including webinars, seminars or events) that are similar or related to products and services that you purchase or use from PSS, as permitted by local law. In addition, if you attend a PSS webinar, seminar or event, or if you purchase a PSS product or service, PSS will contact you to obtain feedback regarding the refinement of the relevant webinar, seminar, event, product or service.


4.4 How does PSS share, transfer, and publicly disclose your information?


4.4.1 Information Sharing

PSS will not share your personal information with companies, organizations and individuals outside the PSS Group, except: (i) after obtaining your explicit consent; (ii) as required by laws and regulations, v. dispute resolution, or as required by law by administrative or judicial authorities; (iii) as required for the disposal of infringement complaints; and (iv) to necessary third parties for the purpose of providing services to you.


4.4.2 Information Transfer

PSS will not transfer your personal information to any company, organization or individual except: (i) after obtaining your express consent; (ii) in the event of a merger, acquisition or liquidation involving the transfer of personal information, we will require the new company or organization holding your personal information to continue to be bound by this privacy policy, or we will require the company or organization to seek your authorized consent again.


4.4.3 Public Disclosure

PSS will only publicly disclose your information (i) with your express consent; (ii) if compelled to do so by law, legal process, litigation or governmental authority.


4.4.4 Exceptions

in the following cases, prior authorized consent is not required for sharing, transferring or publicly disclosing your personal information: (i) related to national security or national defense security; (ii) related to public safety, public health or significant public interest; (iii) related to crime investigation, prosecution, trial and judgment execution; (iv) for the purpose of safeguarding your or other individuals' life, property and other significant legitimate rights and interests but it is difficult to obtain your consent; (v) personal information that you disclose to the public on your own; (vi) personal information collected from lawful public disclosure.


Please note that, according to the law, the sharing or transfer of personal information that has been anonymized and ensures that the recipient of the data cannot recover and re-identify the subject of the personal information is not an act of sharing, transferring or publicly disclosing the personal information to the public, and the storage and processing of such data will not require separate notification to you and your consent.


4.5 How PSS protects your information

PSS attaches great importance to the security of your personal information and will take various reasonable physical, electronic and management security measures to protect your personal information and make the best reasonable efforts to ensure that your personal information will not be leaked, destroyed or lost. These safety protection measures include: 1. setting up a special personal information protection organization; 2. formulating and implementing various safety systems and operating procedures; 3. using various encryption, authentication and de-identification technologies in the process of personal information transmission and storage; 4. taking appropriate inspection and audit measures; 5. providing education and training for employees in terms of safety and legal awareness; 6. signing confidentiality agreements with employees and partner organizations; 7. carrying out data security capacity 7. carry out data security capacity building (such as information network level protection assessment and filing); 8. carry out third-party management system certification; 9. formulate contingency plans for personal information security events and conduct drills, etc.


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