Last updated: December 12, 2024
China privacy notice
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Introduction
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Section 1: Notice of Collection and Use of Personal Information
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Section 2: How We Share, Transfer and Publicly Disclose Personal Information
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Section 3: International Transfers of Personal Information
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Section 4: Data Subjects’ Right
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Section 5: Children privacy
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Section 6: Updates to this Notice
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Annex 1 List of LSEG Entities in the PRC
This China Privacy Notice (this “Notice”) supplements the LSEG Privacy Statement and provides additional information about the processing of personal information by the London Stock Exchange Group (“LSEG", “we”, “us” or “our”, which Refinitiv belongs to) of companies within the territory of the People’s Republic of China (“PRC”) in accordance with the PRC Personal Information Protection Law (the “PIPL”) and as further described below. A list of these LSEG entities, which may be updated from time to time, is set out in the Annex 1 of this Notice.
This Notice applies to any such personal information that is collected to support LSEG’s products and services or relates to contractors, to LSEG’s marketing activities, or to users of LSEG’s products and services. To understand how we protect your data and privacy, this Notice should be read in conjunction with the LSEG Privacy Statement. In case of conflict between the two, this Notice shall prevail. This Notice does not apply to LSEG World-Check products and any World-Check content incorporated into any of LSEG’s products and services.
This Notice uses certain terms that have the meaning given to them in the PIPL. For the purpose of this Notice, relevant terms such as “personal data”, “special categories of data/ sensitive personal information”, “controller”, “processor”, “data subject”, and “supervisory authority” adopted in the LSEG Privacy Statement shall have the meaning given to them as “personal information”, “sensitive personal information”, “personal information processor”, “entrusted party”, “personal information subject” and “authorities performing duties of personal information protection”, respectively, in the PIPL, and in particular:
- “Personal information” is defined by the PIPL as information related to an identified or identifiable natural person recorded electronically or by other means but does not include anonymised information.
- “Sensitive personal information” means personal information that once leaked or illegally used, may easily lead to the infringement of the personal dignity of a natural person or may endanger his personal safety or property, including information such as biometrics, religious belief, specific identity, medical health status, financial accounts, and locational information, as well as the personal information of a minor under the age of 14.
Section 1: Notice of Collection and Use of Personal Information
Please refer to the section entitled “What types of personal information we collect” in the LSEG Privacy Statement for information on the categories of personal information we may collect. We may collect the following categories of personal information about you:
- Name and contact information, such as your first and last name, email address, postal address, phone number, and other similar contact data.
- Employer and Professional Level data, such as the names of your current and/or former employers, job title(s), business contact information, industry, certifications, etc.
- Educational data, such as your education history
- Account credentials, such as passwords and other security information for authentication and access
- Payment information, such as payment card number (credit or debit card), and the security code associated with your payment instrument, if you make a payment
- Identifiers, such as unique identification numbers, cookie identifiers, account numbers, social security numbers, national identifiers, etc.
- In addition to the above personal information, which may be sourced from public sources, additional personal information may be sourced from public sources, as detailed in LSEG Privacy Statement.
In the PRC, we only process personal information in accordance with applicable laws, and only if:
- We have obtained your consent;
- It is necessary for the performance of statutory duties or statutory obligations;
- It is necessary for coping with public health emergencies or for the protection of the life, health, and property safety of a natural person in an emergency;
- The personal information processing is for the purpose of news reporting and supervision by public opinions for the public interest, and the processing is within a reasonable scope;
- The personal information is disclosed by you or other legally disclosed personal information is processed within a reasonable scope in accordance with the PIPL; or
- It is in accordance with other circumstances provided by laws and administrative regulations.
To the extent that “legitimate interests” which we rely on as indicated in the LSEG Privacy Statement is not a recognised legal basis under applicable laws, we will seek your consent or other applicable legal bases as described above to process your personal information. In particular, we rely on your consent for the processing of your personal data for conducting marketing activities.
We may use the categories of personal information listed above for the purposes described in the LSEG Privacy Statement, to the extent required and/or permitted by applicable laws, including as follows:
Purposes | Categories of Personal Information |
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Performing services, including managing our relationship with you as our customers, processing or fulfilling orders and transactions, processing payments, or providing similar services |
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Marketing and promoting our products and services to you, subject to applicable laws |
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Delivering and suggesting tailored content such as news, research, reports and business information |
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Onboarding of, and the management of, our vendors, service providers, business partners, professional advisors and/or other counterparties |
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- We have obtained individual’s separate consent (to the extent the processing relies on consent or as otherwise required by law); and
- We have notified the individuals concerned of the necessity of processing their sensitive personal information and the impact it has on their rights and interests, except where such notification is not required in accordance with the provisions of the PIPL.
We will seek to protect the sensitive personal information rigorously using the security measures required by the applicable law and, hence, your sensitive personal information should not be processed in a way that will result in negative implications to your personal rights, e.g., harm to your reputation, physical or mental health, personal or property security.
Section 2: How We Share, Transfer and Publicly Disclose Personal Information
a. Entrusted Processing and Sharing of Personal Information
We may provide or disclose your personal information for purposes described in Section 1 to certain categories of third parties, in accordance with applicable law. Please refer to the section entitled “How we share personal information” in the LSEG Privacy Statement for further information.
Set out below is a list of key types of third parties, with which we may share your personal information, that can independently determine processing purposes and methods when processing your personal data:
Third parties | Identity and contact details | Processing purpose, method, categories of personal information shared |
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LSEG group companies | please refer to https://www.lseg.com/en/locations | please refer to the respective sections in the LSEG Privacy Statement |
Our customers on a case-by-case basis | To be notified to a data subject by the customer on a case-by-case basis | please refer to the respective privacy policies of these customers for details on what, how and why these customers process your personal data |
b. Transfer
Without your separate consent (to the extent the processing relies on consent or as otherwise required by law), we will not transfer your personal information to any other company, organisation or individual, except in the case of any sale, merger, acquisition, restructure, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceedings) or other similar transaction(s) where the transfer is necessary. In such cases, you will be informed of the name and contact information of the recipient of the personal information in accordance with the requirements of the applicable laws and can expect the recipient to comply with this Notice and the LSEG Privacy Statement. If the recipient changes the purposes or means of processing of personal information, it shall re-obtain the consent from you.
c. Public Disclosure
We will not disclosure your personal information to the public unless we have your separate consent.
Section 3: International Transfers of Personal Information
LSEG is a global organisation and your personal information may be transferred from the PRC to other jurisdictions of the personal data processing activities described in Section 2 above.
With your separate consent where required by law and to the extent permitted by law, your personal information may be processed by a party located outside the PRC. Meanwhile, we will ensure that appropriate measures are taken to make sure that your personal information remains protected, secure or in compliance with applicable overseas data protection laws. To the extent that we rely on the mechanism of adopting a standard contract as approved by the PRC competent data protection authorities for the transfer of your personal information to outside the PRC, you acknowledge that you as personal information subjects are entitled to enjoy rights as a third-party beneficiary under the standard contract, unless you expressly object so within 30 days upon receiving this notice.
Set out below is a list of the key types of overseas recipients with whom we may transfer your personal information outside the PRC:
Primary overseas recipients | Identity and contact details | Processing purpose, method, categories of personal information shared, as well as ways to exercise data privacy rights over the receiving party |
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Third parties that help us delivery services or act on our behalf | Should you require information of these third parties, please contact us using the details set out in the section entitled “How to contact us” of LSEG Privacy Statement | please refer to the respective privacy policies of these third parties |
LSEG group companies | please refer to https://www.lseg.com/en/locations | please refer to the respective sections in the LSEG Privacy Statement |
Our customers on a case-by-case basis | To be notified to a data subject by the customer on a case-by-case basis | please refer to the respective privacy policies of these customers |
Section 4: Data Subjects’ Right
Subject to certain conditions and exceptions, you have certain rights regarding your personal information under the PIPL as described below:
Access: You may have the right to request access to your personal information that is being processed by us.
Rectification: You may have the right to rectify incorrect or incomplete personal information or supplement relevant information.
Deletion: You may have the right to request that we delete certain personal information we have collected from you.
Opt-Out of Marketing: You may have the right to opt-out of receiving marketing communications from us.
Object: You may have the right to object to, and the right to request that we restrict, our processing of your personal information in certain circumstances (including the right to request not to be subject to a decision based solely on automated processing).
Data Portability: In some circumstances where applicable under PRC law, you may have the right to ask for the personal information you have made available to us to be transferred to a designated personal information processor.
Withdraw Consent: You may have the right to withdraw any consent you have previously given us to handle your personal information. If you withdraw your consent, this will not affect the lawfulness of our use of your personal information prior to the withdrawal of your consent.
Explanation: You may have the right to request for explanation of our rules for processing your personal information.
How to Submit a Request:
In order to exercise your rights please visit this site. In response to a request, we will ask you to verify your identity if we need to, and to provide information that helps us to understand your request better.
Verifying Requests:
To help protect your privacy and maintain security, we will take steps to verify your identity before granting you access to your personal information or complying with your request. We may require you to provide any or all of the following information:
- First and last names;
- Email address;
- A copy of certain identification documents; and/or
- Information about your interaction or relationship with LSEG and/or your usage of LSEG’s products and services.
Respond to your request:
Upon receipt of you request, we will respond within the time frame stipulated in applicable laws. There are limits to the rights that you have in relation to your personal information and in certain circumstances we may not be required or able to meet your request, or we may meet your request in part only. Where this occurs, we will provide you with an explanation as to why we are unable or not required to meet your request.
If you have any questions or complaints in relation to your right request, see the “How to contact us” section of the LSEG Privacy Statement for details of how to contact us. If you are not content with how LSEG manages your personal information, you can lodge a complaint with the data protection regulator or submit a lawsuit to the competent people’s court if you think that any of your rights have been infringed by us.
Section 5: Children privacy
Our products and services are not generally aimed at children. We do not intentionally collect personal information from or about individuals under the age of 14; however, in the event that we learn or discover that we have collected personal information inconsistent with LSEG Privacy Statement or this Notice, we will ensure that the processing of such personal information is for a lawful and legitimate purpose and we will make reasonable efforts to delete and remove such personal information following the expiration or termination of the lawful and legitimate purpose.
Section 6: Updates to this Notice
This Notice may be subject to updates. Any material future changes or additions to the processing of personal information as described in this Notice affecting you will be communicated to you through an appropriate channel. For example, we may place a prominent notice on a product site or email you to let you know of any updated Notice.
Annex 1 List of LSEG Entities in the PRC
The London Stock Exchange Group of companies within the territory of the People’s Republic of China that process personal information in accordance with the Personal Information Protection Law, as referred to in the preamble of this Notice, include:
- Refinitiv Technology (China) Co., Ltd
- Refinitiv Technology (China) Co., Ltd BJ Branch (Branch of Refinitiv Technology (China) Co., Ltd)
- Refinitiv Transaction Services Ltd - Beijing Rep Office
- Refinitiv Information Services (China) Co., Ltd
- Refinitiv Information Services (China) Co., Ltd – Beijing Branch (Branch of Refinitiv Information Services (China) Co., Ltd)
- Refinitiv Information Services (China) Co., Ltd - Shenzhen Branch (Branch of Refinitiv Information Services (China) Co., Ltd)
- Refinitiv Information Services (China) Co., Ltd - Shanghai Branch (Branch of Refinitiv Information Services (China) Co., Ltd)
- FTSE Beijing Consulting Co., LTD.
- LSE Beijing Rep Office
You may find more information of these entities in the PRC at: https://www.lseg.com/en/locations