Last updated at 12 May 2022

Equasia Group refers to members of the Equasia consulting group (“Equasia Group”). It consists of the following businesses (each, an “Equasia Group Business”):

• Corporate Advisory
• Legal
• International Administration
• Accounting and Reporting
• Intellectual Property
• Compliance
• Sustainability and Responsibility

Where we refer to an Equasia Group “office”, we are referring to an office of an Equasia Group Business.

Further details of the operating structure and regulatory status of each Equasia Group Business, and applicable legal and regulatory terms, follow below.

Entities and Regulatory status

Hong Kong:

Equasia Ltd

A limited company registered in Hong Kong

Companies Registry no 1502042

Trust and Company Services Registration TC002611

HTF Ltd

A limited company registered in Hong Kong

Companies Registry no 574280

Trust and Company Services Registration TC004910

Bonnard Lawson Consulting Ltd

A limited company registered in Hong Kong

Companies Registry no 2482124

Registered Business Name: Equasia Advisors

People’s Republic of China:

BNLS Law Firm

An independent partnership under Chinese law, affiliated with Equasia Group

Licensed as a PRC law firm in Shanghai, PRC under no 31310000MD0285066B

Shanghai Equasia Consultancy Ltd

上海瑛汇颀商务咨询有限公司

A wholly foreign owned limited company registered in Shanghai, PRC under no 91310115MA1K3MA829

Registered as a Trademark Agent with the Trademark Office of China National Intellectual Property Administration http://wssq.sbj.cnipa.gov.cn:9080/tmsve/agentInfo_getAgentDljg.xhtml

Privacy Policy

Your privacy is important to us. Equasia Group, as defined in our legal and regulatory section, (“Equasia Group”, “we”, or “us”), are committed to protecting and safeguarding any personal information we collect. This document provides Equasia Group’s personal information processing rules, which are based on the privacy and data protection principles common to the countries we operate in (the “Privacy Policy”).

This Privacy Policy is mainly intended to let you know what personal information we may collect about you and how we process that information.

This Privacy Policy applies to the personal information we collect from the website and related subdomains (the “Website”) managed by us, and from when you use any of the services we provide (the “Services”). This Privacy Policy will govern any personal information you provide to us while registering to, or using, the Website and our Services.

Generally, our intent is to collect only the personal information provided voluntarily. Equasia Group does not collect or process any personal information from visitors of the Website that is not voluntarily provided.

This Privacy Policy applies to the personal information we collect through the Website and other means by which we collect data. For example, it also covers how we collect information from in-person discussions, telephone conversations, and non-electronic communications.

Equasia Group collects and processes personal information in the context of providing Services, subject to the applicable data protection and privacy laws and regulations. Please review this Privacy Policy to learn more about how we collect, use, share and protect the personal information that we have obtained.

For the avoidance of doubt, personal information processing includes, but is not limited to, the collection, storage, use, transmission, provision, disclosure, and deletion of personal information.

Acceptance and update of this Privacy Policy

We might amend this Privacy Policy from time to time. Therefore, we encourage you to visit this page regularly to know exactly where you stand. If we make changes to this Privacy Policy that will impact you, such as if we intend to process your personal information for a new purpose other than communicated in this Privacy Policy, we will notify you of these changes before starting further processing activities.

If you disagree with this Privacy Policy, you should discontinue using our Services. Please note we may not be able to provide some of our Services to you if you disagree with the processing of your personal information as described in this Privacy Policy. If you are using the Website and prefer to contact us by phone or pay us a visit in person, please check our information here.

If you have any doubts about this Privacy Policy, you may contact us at any time at the e-mail address provided in item 14.

What kind of information do we collect?

Personal information: Personal information refers to all kinds of information related to identified or identifiable natural persons that are electronically or otherwise recorded, such as your name, e-mail address, ID information, address, other contact details, and online identifiers. We may also collect personal information from third parties that you provide to us.

Usually, we obtain personal information about you if you choose to provide it, such as to contact mailboxes or register for certain services. By registering and/or submitting personal information to Equasia Group, you also acknowledge that Equasia Group may use this information in accordance with this Privacy Policy. Your personal information is not used for other purposes unless we obtain your permission or unless otherwise required or permitted by law or professional standards.

Please note that if you disclose someone else personal information to us, it is your responsibility to ensure the person or people you have provided or will provide personal information about are aware of it and have accepted how Equasia Group uses their information (as described in this Privacy Policy).

We only collect personal information to offer our Services. We may also collect information from your computer, phone tablet, or other devices you are using to access the Website, such as your IP address. Please note that some of these data are necessary for the Website’s functioning.

Sensitive personal information: Sensitive personal information refers to any information that, if leaked or illegally used, could easily lead to the infringement of human dignity or cause harm to an individual or their property, such as financial information, health care information, and personal information of minors under the age of 14.

Equasia Group does not collect sensitive personal information unless strictly necessary to provide the Services. We may only collect your sensitive personal information after specifically obtaining your consent and notifying you of the necessity of the processing and the impacts it might have on your rights and interests.

Other data (excluding personal information): Other data refers to information that cannot be traced back to a specific individual. For example, we may track the number of visitors to our website each day.

Personal information from third parties: We might also receive information about you from other sources when necessary for them to provide you with services or for other reasons, as should be specific in their notices and policies. These include business partners, other members of the Equasia Group corporate family, and independent third parties. We suggest you carefully read any third-party privacy notice and policy to understand how they share your personal information with us.

Equasia Group will process any personal information collected under the provisions of relevant data protection and privacy laws and regulations.

How do we collect and use information from or about you?

We collect information, for example, when you : (i) enter your information via the contact page and submit it to us; (ii) obtain products and/or services from us; (iii) request information from us; (iv) opt-in or subscribe to our newsletter or participate in a campaign; (v) respond to our customer surveys; or (vi) engage one of our business partners to provide you with services or products that require the disclosure of your personal information to us.

Automatic collection: In some instances, Equasia Group and its service providers use cookies, web beacons, and other technologies to automatically collect certain types of information when you visit us online, as well as through e-mails that we may exchange. The collection of this information allows us to customize your online experience, improve the performance, usability, and effectiveness of Equasia Group’s online presence, and measure our marketing activities’ effectiveness.

If you have subscribed to our marketing activities, you shall have the right to opt out anytime if you do not wish to receive any future marketing materials from Equasia Group.

We may also:

· acquire information from public sources or third-party sources, such as our advertising and market research partners, to update or enhance the other information collected about you. Local law may require that you authorize the third party to share your information with us before we can acquire it; and

· automatically acquire information when you reply to or interact with an e-mail we send, such as to track your engagement with our messages or when your replies to our messages contain additional e-mail addresses.

What is the legal basis for processing your personal information?

Equasia Group generally collects only the personal information necessary to fulfill your request. However, where additional, optional information is sought, you will be notified of this at the point of collection.

Relevant data protection and privacy laws from jurisdictions such as the Peoples’ Republic of China, Hong Kong SAR, and European Union, where applicable, allow us to process personal information, so long as we have a ground under the law to do so. Additionally, they require us to tell you what those grounds are. As a result, when we process your personal information, we will rely on one of the following processing conditions:

To provide products or services: We may process your personal information to provide the Services or operate the Website, including providing support and processing your requests, questions, and concerns.

The processing is necessary for the conclusion or performance of a contract that you are a party : We will process your personal information when processing your personal information is necessary to perform our obligations under a contract entered with you.

For conducting human resource management : We will process your personal information when you provide it to us in a recruitment process or if you are part of our staff.

When it is necessary for us to fulfill statutory functions or statutory obligations : We will process your personal information when we are required to do so to comply with a legal obligation, such as keeping records for tax purposes or providing information to a public body or law enforcement agency

You gave us your consent: We may occasionally ask you for separate permission to process your personal information for specific purposes such as to send you e-mails with information about our products and Services, or to ask you for permission to share your personal information with our business partners overseas to enhance the quality of the Services we provide you. We will only process your personal information in this way if you agree to us doing so. You may withdraw your consent at any time by contacting Equasia Group at support@equasia-group.com

How do we use your information?

Based on the legal grounds described above, we usually process your personal information for the following reasons:

· to allow you to use and interact with the Website, and download any informative material we may provide free of charge;

· to communicate with you in response to your requests for information, or as may be relevant for providing the Services to you;

· to send marketing communications related to our products and services;

· to customize the information Equasia Group delivers to you;

· to improve the overall quality of the Website and our Services;

· to count, track, and aggregate your activity into our analysis of general traffic flows at the Website (e.g., tracking where traffic comes from, how traffic flows within the google.com properties, etc.);

· as required by applicable law or legal requirements about records retention or for internal administrative purposes;

· as may be specifically authorized by you from time to time in writing.

Sharing your personal information

We do not share personal information with unaffiliated third parties, except as necessary for legitimate professional and business needs to carry out your requests and/or as required or permitted by law or professional standards.

We may also share your personal information with our affiliates worldwide, who are all governed by this Privacy Policy.

We will share your personal information in situations such as the following:

· Equasia Group works with reputable partners, service providers, or agencies so they can process your personal information on our behalf. Equasia Group will only transfer personal information to them when they meet our strict standards on data processing and security.

· If we are reorganized or sold to another organization, we may also disclose personal information related to the sale, assignment, or other transfer of the site’s business to which the data relates. You will be notified if that happens;

· Equasia Group may, to the extent permitted by the local laws or subject to the fulfillment of the regulatory requirements of the applicable laws, disclose personal information to respond to requests of courts, tribunals, government, or law enforcement agencies.

· Disclosures of personal information may also be needed for data privacy or security audits and/or to investigate or respond to a complaint or security threat.

Other than stated above, we may share your personal information with third parties only under any of the following circumstances:

• when we have your consent to share the information;

· we need to share your information to provide any information, services, or goods at your request;

• we need to share the information to contact you;

· we need to enforce the terms of use of any of the Website or any of our Services;

· in any case of dispute or legal proceeding of any kind between you and any member of Equasia Group;

· if we believe that you have breached the applicable terms of use or have abused your rights to use any of our Services or performed any act or omission that we believe to be violating any applicable law, rules, or regulations;

· in urgent circumstances to prevent physical harm or damage to any person or property; or

· in any other situation as required or authorized by applicable laws and regulations.

Equasia Group will not transfer or disclose the personal information you provide to any third parties for their own direct marketing use.

Prior to entrusting the processing of your personal information, we will agree on the processing methods, categories of personal information, protection measures, and the rights and obligations of both Equasia Group and the third party.

Any third party with whom we may share your personal information will be contractually bound to keep your personal data confidential and appropriately secure.

How is your personal information shared within Equasia Group?

When using our Services, you agree to the collection and/or processing of data by third parties, when necessary, and by the members of the Equasia Group, as described below. We may receive personal information about you from other companies in the Equasia Group, or share your personal data with them, for the following purposes:

• To provide services and products
• To provide customer service

· To detect, prevent, and investigate fraudulence or other illegal activities and data breaches

• For analytical and product improvement purposes

· To send you personalized offers or marketing with your consent, or as otherwise permitted by applicable law

· For hosting, technical support, overall maintenance, and maintaining security of such shared data

• To ensure compliance with applicable laws

As applicable and unless indicated otherwise, for the purposes described above, Equasia Group normally relies on our contractual relationship, on your consent, our legitimate interest (where applicable), or to comply with legal obligations.

All companies within the Equasia Group may need to exchange personal information of our clients to ensure the best delivery of our products and services.

International transfers of personal information

To be able to provide you certain Services, we may process your personal information to third parties in different jurisdictions, including Mainland China, Hong Kong Special Administrative Region (“Hong Kong SAR”) and jurisdictions in Southeast Asia.

When we need to process your personal information overseas, we may rely on different data protection rules based on the applicable laws and regulations. We may rely on, for example, appropriate standard contractual clauses and other mechanisms that are compatible with relevant data protection laws and regulations.

When we need to process your personal information overseas, we will do so after obtaining your separate consent. We will take all the necessary measures to ensure the safety of your personal information. The reasons for the transfer and the categories of recipients of the personal information transferred are stated below.

To provide you our full range of Services, we may need to share your personal information with our business partners who are not located in the same jurisdiction as we are. For example, if you need consulting Services in transactions involving Hong Kong SAR and Mainland China, we may need the support of our partners in Mainland China.

How long we retain your information

We will retain your personal information for the shortest time necessary to achieve the processing purposes, such as to enable you to use our Services, to comply with applicable laws, resolve disputes with any parties, and otherwise as necessary to allow us to conduct our business, including to detect and prevent fraud or other illegal activities. In any case, the retention period will not exceed 10 years.

All personal information we retain will be subject to this Privacy Policy. If you have a question about a specific retention period for certain types of personal information we process about you, please contact us using the contact details provided below in item 14.

How we handle children’s personal information

Equasia Group’s services are not directed at children. We do not knowingly collect personal information from children under the age of 14 without consent from their parent or guardian. We will delete such information if we become aware that it has been submitted by a third party who is not the minor parent or legal guardian.

In case we absolutely need to process children’s personal information to provide you our Services, we will notify the parents or guardian of the necessity of the processing and the impacts on the child’s rights and interests and implement strict security policies.

If you are a parent or guardian and are concerned about our collection of your child’s personal information, please contact us.

Links to other websites

The Website may contain links to sites operated by third parties whose policies regarding handling information may differ from ours. These websites and platforms have separate and independent privacy or data policies, privacy statements, notices, and terms of use, which we recommend you read carefully.

Your rights and how you can exercise them

According to relevant laws, regulations, and national standards, as well as common practices in the jurisdictions where privacy laws apply to Equasia Group’s processing of personal information, you will have the following rights:

· the right to know and to decide on the processing of your personal information;

· the right to restrict or refuse the processing of your personal information;

· the right to consult and duplicate your personal information;

· the right to have your personal information rectified if inaccurate or incomplete;

• the right to change the scope of your consent;

· the right to de-register from our mailing list once you have given us your consent to be in it;

· the right to request the erasure of your personal information, for example, when it is no longer needed for the purposes for which it was collected or processed, or to have it erased when you withdraw your consent; and

· the right to request the portability of the personal information entrusted to Equasia Group on the basis of consent.

To exercise the rights mentioned above, you may contact us directly at support@equasia-group.com and ask us the following: (i) to provide you a copy of your personal information, (ii) to correct your personal information, (iii) to erase or restrict the processing of your personal information, and (iv) to transfer some of your personal information to other organizations. You may also object to our processing of your personal information.

We will acknowledge your e-mail within 3 days and seek to resolve your concern within 1 month of receipt. However, where the issue is complex, or we have a large volume of requests, we will notify you that it will take longer than one month to resolve your concern, and we will seek to resolve it within 2 months. Please note:

· We should be able to determine your identity in order to be able to respond to your request.

· We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.

· We are not obliged to delete personal information if we can show that the processing is required under applicable law or regulation, or, for example, for the establishment, exercise, or defense of a legal claim.

· Where the retention period provided by any law or administrative regulation has not expired, or it is difficult to realize the deletion of personal information technically, we will cease the processing of your personal information and take necessary security protection measures for such information.

· If you provide us with your e-mail address, you will always have the opportunity to opt-out of receiving e-mail newsletters and promotions through the unsubscribe link in the e-mail communications.

· If you do not allow us to collect, or ask us to delete or to stop processing, any of your personal information, we may not be able to provide you with certain features and/or Services, and some of the Website’s features and some of our Services may not work appropriately or adjusted to your interests and preferences.

If you want to exercise any of your rights, you may contact us at support@equasia-group.com

We will not charge for your reasonable requests in principle. However, a fee to reflect the cost may be imposed as appropriate on repeated requests beyond a reasonable scope.

If you are unhappy with our processing of your personal information or you understand there is an alleged infringement of any applicable data privacy laws, you may lodge a complaint with a competent supervisory authority.

How we protect your personal information

Equasia Group is concerned about the security of your data. We have implemented technical and organizational security measures designed to help protect your information from unauthorized access, disclosure, use, and modification. In addition, we review our security procedures to consider appropriate new technologies and methods from time to time.

Please be aware that despite our efforts, no security measures are perfect or impenetrable. As a result, we cannot ensure, and do not warrant or guarantee, that the information you transmit to us will remain secure, nor do we guarantee that this information will not be accessed, disclosed, altered, destroyed, or used in an unauthorized manner.

If we learn of a security breach, we may attempt to notify you electronically so that you can take appropriate protective steps. We may also post a notice on the Website or our Services if a security breach occurs. Depending on where you live, you may have a legal right to receive a notice of a security breach in writing. Depending on the breach, we may also have the right to implement corrective measures, and you may not need to be notified.

Contact Us

If you have any additional questions or concerns about our privacy policy, please contact us at support@equasia-group.com