October 2021

CITIC Telecom CPC Privacy Notice

Introduction

We would like to thank you for visiting our website. We are happy to facilitate your visit as best as we can, therefore we would like to direct your attention towards our Privacy Notice. This Privacy Notice describes CITIC TELECOM CPC 's (as defined under “Who we are”) use of your personal data. We at CITIC TELECOM CPC are committed to respecting your online privacy and recognize your need for appropriate protection and management of any personal data collected by or submitted to us (or carefully selected third parties acting on our behalf).

Below we explain in more detail how we process your personal data. For purposes of this Privacy Notice, "personal data" means any information that relates to you and identifies you personally, either directly or indirectly, alone or in combination with other information available to us.

This Privacy Notice applies to all personal data that is collected and used by us when you visit this website and/or use the products and services offered on this website and interact with us through social media or otherwise.

Who we are

CITIC TELECOM CPC is an international telecommunications provider with its headquarter in Hong Kong, China. We are the preferred partner of multinational corporations (MNCs) and business enterprises for the provision of state-of-the-art information and communications technology solutions. CITIC TELECOM CPC is one of the first service providers to offer private network services in Greater China and Asia Pacific, and serves a wide range of industry customers via multiple branch offices worldwide. All reference to “CITIC TELECOM CPC”, “we” or “us” herein shall include CITIC Telecom International CPC Limited and its subsidiaries, affiliates and associated companies and shall refer as data controller for processing your personal data under this Privacy Notice. In specific the CITIC TELECOM CPC affiliate that you intend to or have entered into an agreement with for the provision of products and services shall be responsible for your personal data – either solely or jointly with its subsidiaries, affiliates and/or associated companies within CITIC TELECOM CPC.

What personal data do we collect?

The types of personal data collected include:

• your first and last name;
• your title and your company's name;
• your home, billing, or other physical address (including street name, name of a city or town, state/province, postal code);
• your e-mail address;
• your telephone number;
• (for job applicants submitting electronic information) your educational background, employment experience, and job interest;
• any other identifier that permits CITIC TELECOM CPC to make physical or online contact with you;
• any information that we collect online from you and maintain in association with your account, such as your username and your password;
• your marketing preferences, including any consents you have given us;
• any other information that you provide to us when you are communicating with us.

We also collect information on the use of our website via cookies. Please view our Cookie Policy for more information.

Whenever we collect personal data directly from you, we will indicate whether the provision of personal data is mandatory. Such will be the case where we require personal data to comply with legal or contractual obligations: if such data is not provided, then we will not be able to manage our contractual relationship, or to meet obligations placed on us.  In all other cases, the active provision of requested personal data is optional.

Personal data directly provided by and about you

The following data is collected directly from you:

• Personal data that you provide to us when you purchases a product or service;
• Personal data which you provide as part of correspondence, feedback, help and dispute settlement.
• Personal data which you provide when you request software downloads;
• Personal data which you provide when you creating a user account (login user name and password) and other information which you enter or provide through the use on our website;
• you request information or materials (e.g., whitepapers or newsletters);
• Personal data which you provide when you participate in surveys, evaluations in promotions, contests and giveaways;
• Personal data which you provide when you apply for a job or submit your resume;
• Personal data which we collect when you use our website through cookies, such as Google analytics.

Personal data we receive from external parties:

Occasionally, our commercial partners and/or third-party service providers may provide personal data to us. If so, we will require such partners and service providers to confirm compliance with the relevant applicable law including confirming that they have informed those individuals of the use, disclosure and transfer of personal data from them to us; and that they have obtained those individuals’ authorisation and/or consent to such use, disclosure and transfer (or the extent to which such authorisation and/or consent was obtained).

For what purpose and on what legal basis do we use your personal data?

We will use your personal data for the following purposes:

• To establish and fulfil a contract with you, for example if you make a purchase from us or download an application. This may include verifying your identity, taking payments, communicating with you, providing customer services and arranging the delivery or other provision of products or services;
• As required by CITIC TELECOM CPC to enable our business and pursue our legitimate interests. In particular:
• we will use your personal data to provide services you have requested, and respond to any comments or complaints you may send us;
• we monitor use of our products and services, and may use your personal data to help us monitor, improve and protect our products, content, services and websites;
• we may use personal data you provide to personalize our products or services for you;
• we may use your personal data for the purposes of ensuring network and information security, including preventing unauthorized access to electronic communications networks and stopping damage to computer and electronic communication systems
• we may monitor any customer account to prevent, investigate and/or report fraud, terrorism, misrepresentation, security incidents or crime, in accordance with applicable law;
• we may use your personal data for market research and marketing purposes;
• we may process data for administrative transfers within a group of companies; and

More information about how we have balanced our legitimate interest with your privacy interests can be obtained upon request via DPO.CITICTelecom-CPC@twobirds.com.

• For compliance with applicable laws and protection of our legitimate business interests and legal rights, including, but not limited to, use in connection with legal claims, compliance, regulatory, investigative purposes (including disclosure of such information in connection with legal process or litigation).
• In addition, we will send you, based on your consent (if required), direct marketing communication in relation to our relevant products and services, or other products and services provided by us, our affiliates and carefully selected partners. You can withdraw your consent at any time ("opt out"); see the section "What rights do you have in relation to your data?" below. In case of electronic direct marketing you can opt out by following the instructions in the communication.

Who will we share this data with?

If necessary to perform a service you request from us, to execute an order you have placed or to follow-up on your enquiries, we will share your information with other CITIC TELECOM CPC subsidiaries, affiliates and/or associated companies, or third-party service providers, for example email and hosting providers, suppliers and delivery services.

We (or any third party on our behalf) disclose or transfer personal data to others as follows:

1. to service providers that provide hosting services and technology service providers, business process outsourcing service providers and call centre service providers;
2. as required in order to establish, exercise or defend or to protect legal claims, including in relation to our contracts with our clients and in order to protect the rights, property or safety of us, our business, any affiliate, our customers or others, including to legal advisors, government and law enforcement authorities and with other parties involved in, or contemplating, legal proceedings;
3. to competent regulatory, prosecuting, tax or governmental authorities, courts or other tribunals in any jurisdiction or markets, domestic or foreign, upon their request or in accordance with or as desirable in respect of any applicable Law;
4. to any other third parties to the extent such disclosure is required under applicable law or to enable products and services to be provided to you and/or our customers;
5. payment infrastructure providers and persons from whom we receive or to whom we make payments on your or our customer's behalf;
6. to prospective sellers or buyers as part of a sale or merger of our or any affiliates business or assets (subject to local laws).

Third party service providers will process your information on behalf of CITIC TELECOM CPC for the purposes above. When we share your data with these parties, we make sure that appropriate safeguards are taken to protect your information.

Where will we send your data?

We may transfer your personal data to our CITIC TELECOM CPC affiliates or third parties (e.g., service providers) overseas, which may involve the transfer of personal data to countries outside the European Union/ European Economic Area which have different data protection standards to those which apply outside the European Union/European Economic Area. For a list of the countries in which we operate, please see here.

Some of these countries are subject to a European Commission adequacy decision. For other countries, we have put in place European Commission approved standard contractual clauses (SCC's) within the CITIC TELECOM CPC group or with the relevant third party to protect this personal data. You have a right to ask us for a copy of the safeguard used (by contacting us via DPO.CITICTelecom-CPC@twobirds.com).

How long do we store your data?

We retain information about you only for as long as we need it for the purposes for which it was collected. After that time your personal data will be erased (unless we have the statutory right or obligation to further keep this data).

For example, if you are a customer of CITIC TELECOM CPC, we will keep your information for the duration of the contractual relationship you have with us, and, to the extent permitted, after the end of that relationship for as long as necessary to perform the purposes set out in this notice. The criteria to determine the storage period are statutory and contractual requirements, the nature of our relationship with you, the nature of the data concerned, technical necessities. Laws may require us to hold certain information for specific periods.

Where we process personal data for marketing purposes or with your consent, we process the data until you ask us to stop and for a short period after this (to allow us to implement your requests). We also keep a record of the fact that you have asked us not to send you direct marketing or to process your data so that we can respect your request in future.

How do we protect your data?

We strive to maintain a high standard of security and have put in place robust technical and organizational measures for the protection of your data in accordance with the current, general state of the art technologies, especially to protect the data against loss, falsification or access by unauthorized third persons. However, the transmission of information via the internet is not completely secure. So, whilst we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our website. Any transmission is at your own risk. Once we have received your personal data we will use strict procedures and security features to prevent unauthorized access.

We have a number of measures in place to ensure the security of digitally stored personal data, such as a strict policy on access authorization, instructions on how to ensure security of personal data, a back-up procedure and secured connections. We also have adequate measures in place to secure personal data on hard copy and to physically secure back-up tapes of our digital data.

Access to your personal data is restricted to individuals who need such access in order to assist with our telecommunications services. We have strict confidentiality obligations that apply to these individuals. Failure to meet these obligations may result in disciplinary and other actions, including dissolution of a contract, termination of employment and criminal prosecution.

What rights do you have in relation to your data?

You have the right to ask us:

• for access to and a copy of your personal data that we hold on you;
• for a copy of the personal information you provided to us and to provide it to you or send to a third party in a commonly used, machine readable format;
• to update or correct your personal data in order to make it accurate;
• to delete your personal data from our records in certain circumstances;
• to restrict the processing of your personal data in certain circumstances;

• object to us processing your personal data in certain circumstances (in particular, where we don’t have to process the data to meet a contractual or other legal requirement, or where we are using the data for direct marketing;
• withdraw your consent at any time, where we are using your personal data with your consent. This will not affect our use of your personal data prior to the withdrawal of your consent.

These rights may be limited in some situations – for example, where we can demonstrate that we have a legal requirement to process your data. In some instances, this may mean that we are able to retain data even if you withdraw your consent.

We hope that we can satisfy queries you may have about the way we process your data. If you have any concerns about how we process your data, or would like to opt out of marketing, you can always contact our Data Protection Officer at DPO.CITICTelecom-CPC@twobirds.com, or visit the CITIC Telecom CPC unsubscription page. When addressing us, please always provide your name, address and/or email address as well as information about your request.

You also have a right to file a complaint with the data protection supervisory authority at your member state or country of residence.

Links on our Website and Social Media Buttons

Our websites may contain links to other websites. CITIC TELECOM CPC does not control these parties, their sites or their privacy practices. This CITIC TELECOM CPC Privacy Notice does not apply to external parties or external web areas and any processing of personal data by parties outside CITIC TELECOM CPC or its Affiliates will not be covered by this Privacy Notice. We encourage you to review the Privacy Notice of any company or website before submitting any Personal Data.

On our website we use the following social media plug-ins: Facebook, Google+, Twitter, LinkedIn, Instagram, Weibo, WeChat, YouTube, Youku and Tencent Weibo. The plug-ins can be identified by the social media buttons marked with the logo of the provider of the respective social media networks.

We have implemented these plug-ins using the so-called 2-click solution. This means that when you surf on our website, personal data will initially not be collected by the providers of these social media plug-ins. Only if you click on one of the plug-ins will your personal data be transmitted: by activating the plug-in, data is automatically transmitted to the respective plug-in provider and stored by them (in the case of US providers your personal data will be stored in the USA). We neither have influence on the collected data and data processing operations conducted by the providers, nor are we aware of the full extent of data collection, the purposes or the retention periods.

Information on the purpose and scope of data collection and its processing by the plug-in provider can be found in the respective data protection policies of these providers, where you will also find further information on your rights and options for privacy protection.

Facebook Inc., 1601 S California Ave, Palo Alto, California 94304, USA:
https://www.facebook.com/privacy/explanation

Google Inc., 1600 Amphitheater Parkway, Mountainview, California 94043, USA:
https://policies.google.com/privacy

Twitter, Inc., 1355 Market St, Suite 900, San Francisco, California 94103, USA;
https://twitter.com/privacy

Instagram LLC., 1601 Willow Road, Menlo Park, CA 94025, USA:
https://help.instagram.com/155833707900388

Sina Weibo Corporation, No.8 Sina Plaza, Courtyard 10, the West, XiBeiWang E. Road, HaiDian District, Beijing 100080, China:
http://mediakit.sina.com/privacy.html

Tencent Weibo Corporation, Tencent Building, Kejizhongyi Avenue, Hi-tech Park, Nanshan District, Shenzhen:
https://www.tencent.com/en-us/zc/privacypolicy.shtml

Tencent International Service Pte. Ltd., 10 Anson Road, #21-07 International Plaza, Singapore 079903:
https://www.wechat.com/en/privacy_policy.html

LinkedIn Corporation, 2029 Stierlin Court, Mountain View, California 94043, USA:
http://www.linkedin.com/legal/privacy-policy

Cookies

For more information about our use of cookies, please view our Cookie Policy.

Google Analytics

Our website uses Google Analytics, which is a web analytics service provided by the third-party provider Google, Inc. (“Google”). Google Analytics is used for the purpose of evaluating your use of our website, compiling reports on website activity and other services relating to website activity and internet usage. The information generated by the cookie about your use of the website is usually transmitted to and stored by Google on servers in the United States. This transfer is covered by a separate data processing agreement that we have concluded with Google.

Changes

CITIC TELECOM CPC has pledged to adhere to the fundamental principles of privacy and data protection. We therefore regularly review this Privacy Notice in order to ensure that it is free of errors and clearly visible on our websites, that it contains appropriate information about your rights and our processing activities, and that it is implemented and is compliant with applicable law.

We may update this Privacy Notice from time to time to keep it up to date, to keep pace with new developments and opportunities relating to the Internet and to stay in line with applicable law. If we make significant changes to this Privacy Notice, we will inform you by posting a notification on our website along with an updated version of the Privacy Notice. All handling of personal data will be governed by the most recent version of this Privacy Statement, available on our website. If there is any inconsistency between this English version and other language versions of this Privacy Statement, this English version shall always prevail.

If you have any questions about your data

CITIC Telecom CPC has appointed Bird & Bird DPO Services SRL as a Data Protection Officer (DPO) and may be reached:

• by using the following email: DPO.CITICTelecom-CPC@twobirds.com;
• by mail at the following address: Bird & Bird DPO Services SRL, Avenue Louise 235 b 1, 1050 Brussels, Belgium

Key contact: Vincent Rezzouk-Hammachi

We will address your possible concerns and attempt to resolve any problem.

Version updated October 2021