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This addendum (“Addendum”) supplements the Digital Edge Privacy Statement and Practices (“Privacy Statement”) and sets forth, in greater detail, the information related to how Chuanjun Electronic Technology (Shanghai) Co., Ltd. and its direct and indirect subsidiaries (hereafter “Digital Edge”) processes personal data of users in the People’s Republic of China (“PRC”, for the purpose of this Addendum, excluding Hong Kong Special Administrative Region, Macau Special Administrative Region, and Taiwan) under the applicable privacy regulations in the PRC. The Addendum constitutes an integral part of the Privacy Statement.

Where we will seek your consent

Notwithstanding Section 1 of the Privacy Statement, we will obtain your consent to collect, use, share, transfer (including but not limited to overseas transfer), disclose or otherwise process your Personal Data (which term where used in this Addendum shall be deemed to include reference to Sensitive Personal Data) if and to the extent required by the applicable laws. Where required, we will obtain your explicit and/or separate consent for Processing of your Personal Data, including but not limited to disclosing your Personal Data with any third parties, overseas transfer of your Personal Data, direct marketing, Processing of your Sensitive Personal Data, etc. (if any).

Processing of Sensitive Personal Data

“Sensitive Personal Data” refers to data which, if breached, illegally provided or abused, may threaten personal or property safety and easily result in damage to personal reputation, or physical/mental health, or discrimination. Examples of Sensitive Personal Data include (but are not limited to) biometric data, religion, specific social status, medical health information, financial accounts, tracking/location information; and personal data of children 14 years of age or under.

Notwithstanding Section 2 of the Privacy Statement, we will seek your separate consent for Processing of your Sensitive Personal Data (if any) and implement appropriate protective measures to safeguard your Sensitive Personal Data.

Use of your Personal Data

We will obtain your consent if we would like to Process your Personal Data for purposes other than those stated in the Privacy Statement.

Automated decision making

Any analytics or evaluation based on computer program around behavior, interests, hobbies, credit information, health or decision-making activities, are transparent, open and fair, and do not apply any differential treatment between individuals.

You may opt out customized or personalized marketing conducted based on automated decision making. You may also request us to provide an explanation on any decisions that may materially impact you based on automated decision making, and deny our decision made solely based on automated decision making.

Disclosure of Personal Data to third parties

Notwithstanding Section 5 of the Privacy Statement, with your separate consent, we may disclose or share your Personal Data to third parties as below.

Fesco 北京外企人力资源服务有限公司 Beijing Foreign Enterprise Human Resource Service Co., Ltd.

  • Contact: 北京市朝阳区朝阳门南大街14号, No. 14 Chaoyangmen South Street, Chaoyang District, Beijing, +86 10 8569 1286
  • Purpose of use of personal information by the person receiving personal information: Payroll, bookkeeping and tax related services on behalf of Digital Edge.
  • Means and Method of Disclosure: Personal information is encrypted using a safe security server after collection and transferred to data server through information and communications network as required.
  • Categories of personal information transferred: For Employees and candidates for employment: name, age, bank account details, employee ID, dependents, passport, family relation certificate, employment agreement, contact information (phone, address, email, etc) and salary information. For suppliers and third partiesAny details included on invoices, including VAT number, bank details, transaction details related to the goods and services acquired by or from Digital Edge.

北京外企德科人力资源服务上海有限公司 Fesco Adecco Human Resources Service Shanghai Co., Ltd.

  • Contact: 上海市黄浦区中山南路28号久事大厦附楼, Annex building, Jiushi Building, No. 28, Zhongshan South Road, Huangpu District, Shanghai, +86 21 6358 9999
  • Purpose of use of personal information by the person receiving personal information: Payroll, bookkeeping and tax related services on behalf of Digital Edge.
  • Means and Method of Disclosure: Personal information is encrypted using a safe security server after collection and transferred to data server through information and communications network as required.
  • Categories of personal information transferred: For Employees: name, age, bank account details, employee ID, dependents, passport, family relation certificate, employment agreement, contact information (phone, address, email, etc) and salary information. For suppliers and third parties: Any details included on invoices, including VAT number, bank details, transaction details related to the goods and services acquired by or from Digital Edge.

首优咨询(北京)有限公司First Advantage (Beijing) Co., Ltd

  • Contact: 北京市朝阳区酒仙桥路甲16号新港大厦1118室, Room 1118, New Port Tower, No. 16, Jiuxianqiao Road, Chaoyang District, Beijing, 010 65505506
  • Purpose of use of personal information by the person receiving personal information: To conduct reference checks for hiring purpose.
  • Means and Method of Disclosure: Personal information is encrypted using a safe security server after collection and transferred to data server through information and communications network as required.
  • Categories of personal information transferred: name, telephone number, email address, ID, nationality, address, working experience, contact and employment information (including details of compensation) relating to previous employment education history and proof For suppliers and third parties: Any details included on invoices, including VAT number, bank details, transaction details related to the goods and services acquired by or from Digital Edge.  

上海开源智造软件有限公司OS Consulting Group Limited

  • Contact: 上海市杨浦区国定东路200号2号楼5层, 5th Floor, Building 2, No. 200, Guoding East Road, Yangpu District, Shanghai
  • Purpose of use of personal information by the person receiving personal information: To conduct business workflow testing in Digital Edge’s ERP system.
  • Means and Method of Disclosure: Personal information is encrypted using a safe security server after collection and transferred to data server through information and communications network as required.
  • Categories of personal information transferred: Contact Details: correspondence and business address, telephone number, email address, Work Order Details: records of work orders placed on our Customer Portal. Data Relating to Our Websites: your device type, operating system, browser type, browser settings, IP address, language settings, date and time of connecting to a Site.

Cross border transfer of Personal Data

Notwithstanding Section 1 of the Privacy Statement, we may, with your explicit and separate consent, transfer your Personal Data to recipients located outside of China, and your Personal Data may be stored in or accessed from outside of China, pursuant to legally acceptable mechanisms that are aimed at ensuring an adequate level of protection as regards your Personal Data under applicable laws, including but not limited to putting in place appropriate contractual agreements with the data recipients, and any other necessary measures to ensure the data recipient’s data processing activities comply with standards comparable to those set out under the applicable PRC laws and regulations.

We provide below the relevant information in relation to the cross-border transfer of your Personal Data:

Digital Edge (Singapore) Pte Ltd.

  • Country to which personal information is transferred: Singapore
  • Contact detail: 6 Temasek Boulevard, #10-05 Suntec Tower Four, Singapore 038986 / john@digitaledgedc.com
  • Time and method of transfer of personal information: Personal information is encrypted using a safe security server after collection and transferred to data server through information and communications network as required.
  • Categories of personal information transferred: E-mail address, encrypted password(s), name(s), phone numbers, registered social media (Line, WhatsApp, LinkedIn, etc.), address, and services acquired.
  • Purpose of use of personal information by the person receiving personal information: Storage and management of collected personal information of suppliers and third parties, Hosting and IT support, Business support – central support functions (service support, billing, communications, marketing, hiring of potential candidates and undertaking background checks, etc), Global business analysis of central support function at the Digital Edge Group level.
  • Period of retention and use of personal information by the person receiving personal information: Retain in accordance with Digital Edge Group data retention policy, (except where it is necessary to retain personal information under the relevant laws and regulations).

Digital Edge (Hong Kong) Limited

  • Country to which personal information is transferred: Hong Kong
  • Contact detail: Level 24, Central Plaza, 18 Harbour Road, Wan Chai, Hong Kong  / john@digitaledgedc.com
  • Time and method of transfer of personal information: Personal information is encrypted using a safe security server after collection and transferred to data server through information and communications network as required.
  • Categories of personal information transferred: E-mail address, encrypted password(s), name(s), phone numbers, registered social media (Line, WhatsApp, LinkedIn, etc.), address, and services acquired.
  • Purpose of use of personal information by the person receiving personal information: Same as above.
  • Period of retention and use of personal information by the person receiving personal information:  Same as above.

Cloudstaff Pty Ltd

  • Country to which personal information is transferred: Australia | Philippines
  • Contact detail: Level 11, 1 Margaret Street, Sydney, NSW 2000/  jaehyunl@cloudstaff.com
  • Time and method of transfer of personal information: Personal information is encrypted using a safe security server after collection and transferred to data server through information and communications network right away.
  • Categories of personal information transferred: Name, Surname, Address, Email Address, Telephone no., IP address, data collected on Digital Edge’s Customer Portal (Odoo.com).
  • Purpose of use of personal information by the person receiving personal information: General support service via chat service. Our Helpdesk staff and engineers may access this information in a limited and reasonable manner in order to solve any issue with our services, or at your explicit request for support reasons, or as required by law, or to ensure the security of our services in case of violation of our Acceptable Use Policy in order to keep our services secure.
  • Period of retention and use of personal information by the person receiving personal information: 2 years.

Odoo Limited

  • Country to which personal information is transferred: Singapore (production server) and Canada and France (backup server)
  • Contact detail: Odoo S.A. – Data Protection, Chaussée de Namur, 40
    1367 Grand Rosière, Belgium | privacy@odoo.com
  • Privacy Policy: www.odoo.com/privacy
  • Time and method of transfer of personal information: Personal information is encrypted using a safe security server after collection and transferred to data server through information and communications network as required.
  • Categories of personal information transferred: Email address, name, postal address, telephone number(s), IP addresses, job applications (and if we decide to send you a job offer, we will also ask you to provide extra personal details as required to fulfill our legal obligations and personnel management requirements), browser language and geolocation.
  • Purpose of use of personal information by the person receiving personal information: Odoo does not use the personal data directly but provides cloud-based ERP Software as a service to Digital Edge which will use the data to support sales, operations, and billing services for our suppliers, customers and manages our Human Resource Information System, including our recruiting process.
  • Period of retention and use of personal information by the person receiving personal information: Information will be stored on the supplier’s server as long as the business need and will be accessed by Digital Edge’s personal only.

Metabase, Inc.

  • Country to which personal information is transferred: Virginia, USA
  • Contact detail: 660 4th Street, #557, San Francisco, CA 94107 / legal@metabase.com
  • Privacy Policy: www.metabase.com/privacy/
  • Time and method of transfer of personal information: Personal information is encrypted using a safe security server after collection and transferred to data server through information and communications network as required.
  • Categories of personal information transferred: Email address, name, postal address, telephone number(s), IP addresses, browser language and geolocation and other anonymized data which can be found at: www.metabase.com/docs/latest/information-collection.html.
  • Purpose of use of personal information by the person receiving personal information: Metabase does not use the personal data directly but provides cloud-based business intelligence/data visualization software as a service to Digital Edge which will use the data to support decision making and operations.  Metabase uses anonymized data to improve on the products and services offered to Digital Edge.
  • Period of retention and use of personal information by the person receiving personal information: Information will not be stored on Metabase’s servers – once the service or script is complete, the information is deleted and no longer stored or accessible on Metabase’s servers.

Trustifi LLC

  • Country to which personal information is transferred: Singapore
  • Contact detail: Trustifi LLC, 6543 S Las Vegas Blvd, Las Vegas, NV 89119
  • Privacy Policy: www.trustifi.com/privacy-policy-2/
  • Time and method of transfer of personal information: Personal information is protected for both in transit and in rest by market standard’s encryption.
  • Categories of personal information transferred: E-mail address, E-mail content, Names and email addresses of senders/ recipients of emails; Photographs, images, and videos; Device identifiers – such as the Internet Protocol (IP) address and other types of unique device identifiers.  Personal information which is collected and processed by Trustifi may also include sensitive data, which may reveal your ethnic origin, health data, religion, sexual orientation, etc.
  • Purpose of use of personal information by the person receiving personal information: Scan and encrypt files and email content to identify and filter out potential phishing attempts and viruses. As part of the scanning process, Trustifi may have access to various types of personal information set forth above, however, they will only use and process such information for the sole purpose of providing the services to Digital Edge (namely anti-phishing and anti-virus scanning).
  • Period of retention and use of personal information by the person receiving personal information: For as long as necessary to provide the services to Digital Edge, and as necessary to comply with Trustifi’s legal obligations, resolve disputes, and enforce our policies. Retention periods will be determined to take into account the type of information that is collected and the purpose for which it is collected, bearing in mind the requirements applicable to the situation and the need to destroy outdated, unused information at the earliest reasonable time.

Microsoft Regional Sales Pte Ltd.

  • Country to which personal information is transferred: Hong Kong and Singapore
  • Contact detail: Microsoft Data Protection Officer, One Microsoft Place, South County Business Park, Leopardstown Dublin 18 D18 P521, Ireland
  • Privacy Policy: privacy.microsoft.com/en-US/
  • Time and method of transfer of personal information: Data is transferred to supplier’s servers in encrypted tunnel and stored on the server with industrial lead encryption algorithm.  The information will be transferred to the server from time to time.
  • Categories of personal information transferred: Email address, name, postal address, IP address, email content, Personal information may also include sensitive data, which may reveal your ethnic origin, health data, religion, sexual orientation, etc.
  • Purpose of use of personal information by the person receiving personal information: Microsoft provides cloud-based office suite used by Digital Edge, consisting of client software applications and connected experiences designed to enable customers like Digital Edge to create, communicate, and collaborate more effectively.
  • Period of retention and use of personal information by the person receiving personal information: Information will be stored on Microsoft’s server as long as necessary to provide the products and fulfill the transactions requested by Digital Edge, or for other legitimate purposes such as complying with its legal obligations, resolving disputes, and enforcing its agreements with Digital Edge. Because these needs can vary for different data types, actual retention periods can vary significantly.

Nuroho Software Consulting

  • Country to which personal information is transferred: Singapore
  • Contact detail: Jl. Margorejo Indah XV, Margorejo, Kec. Wonocolo, Kota SBY, Jawa Timur 60238, Indonesia
  • Telephone: +62(811)353-9003
  • https://nurosoft.id/
  • Time and method of transfer of personal information: Personal information is encrypted using a safe security server after collection and transferred to data server through information and communications network as required
  • Categories of personal information transferred: Contact Details: correspondence and business address, telephone number, email address, Work Order Details: records of work orders placed on our Customer Portal. Data Relating to Our Websites: your device type, operating system, browser type, browser settings, IP address, language settings, date and time of connecting to a Site.
  • Purpose of use of personal information by the person receiving personal information: For PT. Nuroho Software Consulting to conduct business workflow testing.
  • Period of retention and use of personal information by the person receiving personal information: Information will not be stored on Nuroho Software Consulting’s servers – once the service or script is complete, the information is deleted and no longer accessible by PT. Nuroho Software Consulting.

You may exercise your data subject rights as specified in Section 13 of the Privacy Statement.

Data retention

Notwithstanding Section 12 of the Privacy Statement, we will keep your Personal Data for as long as necessary for the fulfillment of the purpose for which it is used, unless applicable law permits or requires a longer retention period.

Children’s privacy

Notwithstanding Section 17 of the Privacy Statement, we do not Process any Personal Data of children under the age of 14.

Contact

If you have any questions or inquiries in relation to this Privacy Statement, or would like to exercise your data subject rights, please direct your questions, inquiries or requests to:

William Zhang

Tel: +86 21 8013 5118

Email: William.zhang@digitaledgedc.com

Address:  2350, Level 23, 5 Corporate Avenue, 150 Hubin Road, Shanghai 20021, P.R.China.

Last updated: 18 July 2023