Depending on which entity you are contracting with, receiving services from or interacting with, Allegis Group Technical Services (Shanghai) Co., Ltd., Allegis Talent Consultancy (Shanghai) Co, Ltd. or Allegis Technology Service (Shanghai) Co., Limited ("we", “our” or “us”) is the processor of your personal information and is committed to safeguarding your privacy along with the other companies in our group (which include those listed here, collectively, "Allegis Group"). “Personal Information” consists of information which refers to various information related to an identified or identifiable natural person but excludes anonymised information. This Privacy Notice ("Notice") is designed to assist you in understanding how we collect, use, disclose, share, and safeguard your Personal Information, and to explain the choices and rights that are available to you. If you have any questions about this Notice, please contact us using the contact details provided below at ‘Contact Us’.

Individuals who are not residents of the People’s Republic of China (the “PRC”) can access additional Privacy Notices by country here. 

We are committed to ensuring this Notice is accessible to individuals with disabilities. If you wish to access this Notice in an alternative format, please contact us at Apac.Privacy@allegisgroup.com. 

Allegis Group forms partnerships with organizations across the globe to optimize talent attraction and retention. We work with clients to help them achieve their talent strategies and business goals, and we help potential candidates fulfil their career aspirations.

Our services include:

• Staffing, Recruiting and Search: Temporary staffing, temp-to-perm and direct placement/search of talent, including candidate recruitment, career counseling and guidance to candidates and job seekers as well as knowledge research by working with clients, candidates and job seekers to conduct research in the market regarding talent and workforce needs and dynamics.
• Managed Delivery: Managed, project-based and out-sourced delivery services for IT, engineering, clinical and sales and marketing initiatives

Learn more about the specific services for each of Allegis Group’s brands at https://www.allegisgroup.com/en/brands (collectively, “Services”).  

This Notice applies to Personal Information we collect online and offline:

• through our website(s), email and related applications and content that link or refer to this Notice (including Allegis Group websites and Allegis computer or mobile software applications (“apps”) and content made available to you) (collectively, the “Sites”);
• over the phone; and
• in person.

In some cases, we may provide additional data privacy notices specific to certain services, practices, or regions. Those terms are to be read in conjunction with this Notice. This Notice also applies when we are receiving services you are providing to us. This Notice does not apply to the practices of third parties that Allegis Group does not own or control.

Our Sources of Personal Information Include:

• Information you submit to us: Where we request information from you, we will inform you prior to collection whether the provision of the Personal Information may be provided on a voluntary basis, and the consequences of not providing the information, which may include being unable to properly provide you with Services.
• Information we collect automatically: We automatically collect certain technical information from you when you visit our Site(s) (for example your IP address, browser and operating system details and actions you take on the Site(s)).
• Information we obtain from other parties: We may receive or acquire information about you from other parties such as: 
  • Websites and services like job boards and professional network sites (for example, zhaopin.com or Lie Pin) and social media platforms and websites where you post information;
  • Clients (for example, for our search services, a client may provide current or prospective candidates for us to consider for a job they have asked us to fill);
  • Business intelligence sources, including data aggregators and list providers;
  • Your referrals (for example, a referral who refers you to us for a potential job opportunity);
  • Trade journals and news sources (for example, industry publications);
  • Public government filings; and
  • Allegis Group affiliates, which are companies that have ownership in Allegis Group, that are owned by Allegis Group, or are under common control with Allegis Group.

Any Personal Information you provide to a third party will be subject to that third party’s privacy notice and our independent use of the Personal Information we obtain from such third parties will be subject to this Privacy Notice. 

• Identifying Information and Contact Information including your email address, telephone number, postal address and contact information of any referrals, references or emergency contacts you provide.
• Educational and Professional Background Information: including your resume or C.V., employment history, education history, certifications, professional license information (for example, bar registration number), languages proficiencies, security clearance information, professional association memberships, volunteer activities, client information where relevant (for example, we may collect information from attorneys we place through our staffing and search business regarding clients the attorney has performed services for) and work-related skills, practice details and skills assessment information including personality characteristics / traits which you choose to provide on a voluntary basis.
• Career Planning Information: including your career interests, desired compensation and benefits, desired work location and willingness to relocate, family information as it relates to your career goals or plans, and hobbies and interests.
• Demographic Information: including your gender, date of birth, and national origin where we are required to or permitted to do so by law.
• Audio, Visual or Similar Information: including photos that you provide to us or that you make publicly available on the internet (for example, zhaopin.com, Lie Pin or company/firm websites); and your image from a security camera if you visit one of our locations.
• Device Information: including your IP address, browser type and version, time zone setting, browser plug-in types and versions, location information on a city-regional basis and operating system and platform information when you are visiting our Site(s).
• Other Information You Provide: including any other Personal Information you may elect to provide to us.

• Visitors: if you are visiting or using our Site(s) or office locations or any of our Services, so that we can provide you with the Site(s) or Services you require;
• Job seekers and Candidates: if you apply for or we contact you about job opportunities with Allegis Group to fill our internal positions or positions through our staffing and recruiting services or search, workforce management, or talent advisory services (once you have been identified for a specific position with us to fill our internal roles or to fill staffing positions with our clients you should view our notices and policies for job applicants and employees mentioned in the Introduction section above);
• Customers, vendors, service providers, and other suppliers: if you are an employee, representative and/or agent of our customers, service providers, vendors, and other suppliers or individuals with whom we have a business relationship and/or manage on behalf of our customers (for example through our outsourcing, MSP and consulting services); and
• Referees and others who advise on the suitability of job seekers: if you submit any Personal Information relating to other people to us or to our service providers in connection with our Services, you confirm that you have the authority to do so and to permit us to use the information in accordance with this Notice.

You may be asked for types of Personal Information that are viewed by the Personal Information Protection Law as sensitive Personal Information. The Personal Information Protection Law defines sensitive Personal Information as information that includes, but is not limited to, biometric identifiers, religious faith, particular identities, medical care and health, financial status, and location tracking, etc., as well as the Personal Information of minors under age 14. 

In limited circumstances, we may collect financial information from you when assessing your suitability for a position. For example, when placing a candidate into permanent positions, we may discuss the candidate’s current compensation. Allegis Group will process any sensitive Personal Information in accordance with applicable data protection laws, including, for example, obtaining required consents. 

We will seek to protect such 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.

We collect and use your Personal Information for our business and commercial purposes, which include:

• Recruiting and Hiring for current and future job opportunities with us or with our customers, including determining your eligibility and suitability for such opportunities.
• Providing our Services, including our staffing and recruiting services as well as our outsourcing service, managed service, various consulting, advisory, transformation and workforce management services. For a description of our Services, click here. 
• Receiving Services, including receiving services from various vendors, suppliers, service providers and contractors.
• Operating and Improving our Site(s), for example, we use your device and information you provide to establish and maintain an account for you on our Site(s) and to improve the navigation and usage of our Site(s).
• Business Sales Development, for example, using your contact information to call or email you as a talent candidate, customer or prospect as part of providing our Services.
• Marketing and Promotions, including sending you promotional communications such as newsletters, surveys, articles of interest, press releases and job fair or other event announcements and personalizing and delivering content about our Services to you, including through advertisements on our Site(s) and other websites.
• Improving Our Services through business analytics, internal audits, troubleshooting, quality control and internal user acceptance testing to improve our search and match capabilities in matching job seekers to suitable jobs efficiently and effectively.
• Research and Thought Leadership, including articles regarding customers and candidates, and white papers, podcasts and other thought leadership regarding workforce, talent and industry trends and analysis.
• Aggregation and Anonymization, including the process of using Personal Information to create aggregated or anonymized data sets for the purpose of internal business analysis or thought leadership with the end product of such data sets not being Personal Information since it is not identifiable to an individual.
• Security and Fraud Prevention to ensure the security of our Site(s) and Services, to protect against fraud, and to comply with legal requirements.
• Compliance with Laws, Legal Action and Professional Advice, including compliance with all laws and regulations and addressing legal action or taking professional advice, for example from attorneys or tax professionals.

If you are in the People’s Republic of China, our legal basis for processing Personal Information about you will depend on the type of Personal Information and the purpose for which we collect it. Processing of your Personal Information is permitted under applicable law because:

• We have obtained your prior consent to do so;
• It is necessary to conclude or fulfill a contract; 
• The Personal Information was disclosed by you or otherwise already lawfully disclosed within a reasonable scope in accordance with the provisions of the Personal Information Protection Law; or
• It is necessary to fulfill statutory duties and responsibilities or statutory obligations.

Processing Based on Consent and Withdrawal of Consent

Where Personal Information processing is based on consent, you have the right to withdraw your consent at any time by completing the web form here. When possible and lawful, we will take reasonable steps to comply with your request. If you choose not to provide us with your Personal Information, we may not be able to provide you with the Services or assistance you require, including arranging suitable interviews for you, as some Personal Information is necessary for the provision of Services. 

Your consent shall be obtained again if a change occurs in the purpose of processing Personal Information, the method of processing, or the categories of Personal Information processed.

We do not sell your Personal Information, but, subject to restrictions under applicable data protection laws, we may disclose certain categories of Personal Information about you for the business purposes mentioned in this Notice to the following categories of third parties:

• Potential Employers or Potential Customers – We may disclose your contact information, professional and work eligibility information, career planning information, demographic information, and other information you ask us to disclose to a customer for the purpose of providing our Services for opportunities we believe are of interest to you. Customers of Allegis Group will process such Personal Information in accordance with their own policies and procedures.
• Vendors, Contractors, and other Service Providers – We use vendors, contractors, and other service providers to assist us in providing our Services, and it may be necessary for us to provide access to some of the categories of your Personal Information (for example, IT operating system and platform vendors who support our systems, SaaS vendors such as applicant tracking systems, customer relationship management systems and back office systems, assessment services, marketing services vendors, attorneys and accountants as well as premises and other security management vendors, including video security at our office locations). These companies will have access to your Personal Information as necessary to perform their functions, but they may only use that information for the purpose of providing the services and are obligated to protect the Personal Information.
• Allegis Group Affiliates – We may disclose your Personal Information to Allegis Group affiliates, which are companies that have ownership in Allegis Group, are owned by Allegis Group, or are under common control with Allegis Group, for example, to match you to job opportunities and/or to utilize shared service functions within Allegis Group.
• Business Transfer Partners – Circumstances may arise where, whether for strategic or other business reasons, Allegis Group decides to sell, buy, merge, or otherwise reorganize businesses. Such a transaction may involve, in accordance with applicable law, the disclosure of Personal Information to prospective or actual purchasers, or the receipt of it from sellers. It is Allegis Group’s practice to seek and provide appropriate protection for Personal Information in these types of transactions.
• Vital Interests and Legal Rights – We may collect and possibly share any or all of the categories of Personal Information in order to establish or exercise our legal rights or defend against legal claims or investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, or violations of Allegis Group’s terms of use or this Notice.
• Courts, Regulators, Law Enforcement and Government Authorities – We may disclose your Personal Information where we are legally required to do so in order to respond to or comply with any applicable law, regulation, subpoenas, court orders, legal process, or government requests, including in response to public authorities to meet national security or law enforcement requirements.
• With Your Consent – We may disclose any or all of the categories of your Personal Information for other purposes with your consent.
• Your Referees and current and former employers.
• Any Other Third Party notified to you at the time of collecting your Personal Information.

Please note that if you post any Personal Information in a public area of our Site(s), the information that you share will be visible to others and can be read, used, or collected by others. We are not responsible for the way others may use Personal Information you post to public areas of the Site(s).

We respect your privacy rights related to the Personal Information we collect, store, use, process, transfer or transmit, provide, disclose, and delete about you and we will comply with applicable data protection laws and regulations in the handling of your Personal Information. The availability of these rights and the ways in which you can exercise them are set out below.

Under certain conditions, you have the right:

• to be informed of our processing activities and to make decisions with respect to your Personal Information in accordance with applicable law; 
• to consult and copy your Personal Information;
• to correct, complete, or supplement your Personal Information if the information we hold is inaccurate or incomplete; 
• to request the deletion of any Personal Information that we no longer have a lawful ground to use; if deletion is technically unfeasible or we are required by law to keep the information longer, we will stop all processing activities in connection with your Personal Information except for storing the same by taking necessary security measures;
• to limit or refuse the processing of your Personal Information in accordance with applicable law; 
• to request that we explain our processing rules for your Personal Information;
• to request us to transfer your Personal Information to the personal information handler you designate when the legal conditions for such transfer are satisfied;
• to object to direct marketing (including any profiling for such purposes); and
• to request us to explain decisions that have significant impact on your rights and interests and are made through automated decision-making technologies, and to refuse decisions made solely via automated decision-making technologies.

When a natural person is deceased, their next of kin may, for the sake of their own lawful, legitimate interests, exercise the rights provided in this Notice to consult, copy, correct, delete, etc., the Personal Information of the deceased, except where the deceased has arranged otherwise before their death.

Your exercise of these rights is subject to certain exemptions and limitations required or permitted by law.

Automated Decision Making

We do not utilize any automated decision-making tools when providing Services to you: that is the processing of your Personal Information done entirely by a computer or without any human intervention. Should this change, we will notify you according to the Changes to this Notice and Effective Date of Notice section below. You have the right to object to any wholly automated processing of your details. 

How to Exercise Your Privacy Rights

If you would like to exercise any of your privacy rights, please complete the web form here.

For all requests, after submitting the request, we will require additional information to reasonably verify your identity depending on the nature of your request.

We will abide by all applicable legal requirements for deadlines for responding to your request and will collect the minimum Personal Information necessary to verify your identity.

If you experience any issues with the web form or phone number, please contact APAC.Privacy@allegisgroup.com. 

Your Right to Opt-Out from Marketing Communications

Where it is in accordance with your marketing preferences and applicable data protection laws, we may periodically send you updates via e-mail or text about promotional opportunities or Services we think may interest you, such as newsletters, white papers, surveys and event information.

You can opt-out of receiving marketing emails from us by clicking the unsubscribe link contained in such emails.  If you continue to have issues in unsubscribing from marketing emails from us, you may submit the form mentioned above and request to opt-out.

Allegis Group websites use cookies, tracking pixels, web beacons and similar technologies (collectively “cookies”) to help personalize your online experience and for analytics purposes. For more information about cookies, the types of cookies we use, how we use them and how to change your cookie settings , please see our Cookie Notice.

We are committed to protecting the Personal Information you share with us. We use appropriate physical, technical, organizational and administrative security measures to help protect your Personal Information from unauthorized or unlawful access, use, or disclosure, and from accidental loss, destruction, or damage.

We retain Personal Information we collect from you where we have an ongoing business need to do so (for example, to provide you with the Service you have requested, to maintain you in our talent pool to be potentially contacted about other employment opportunities, or to comply with applicable legal, tax or accounting requirements).

When we have no ongoing business need to process your Personal Information, we will either delete or anonymize it or, if this is not possible (for example, because your Personal Information has been stored in backup archives), then we will securely store your Personal Information and isolate it from any further processing until deletion is possible. 

Within the Allegis Group Network

As part of a global company, we may transfer your Personal Information to affiliates within the Allegis Group network of companies, a list of whom can be found here. Allegis Group affiliates receiving your Personal Information may be located inside and outside of the PRC. 

Outside Allegis Group and the Allegis Group Network

When providing Services to you, we may share your Personal Information with different types of companies, including third party service providers and Allegis Group customers. These recipients may be located inside or outside of the People’s Republic of China. 

For a complete list of data recipients that are located inside the People’s Republic of China, please click here.

For a complete list of data recipients that are located outside of the People’s Republic of China, please click here.

Before we transfer your Personal Information outside of the People’s Republic of China, we will meet the applicable requirements of laws and regulations of the PRC on cross-border transfer of Personal Information and will require overseas data recipients to protect your Personal Information at the levels not lower than those required by applicable laws and regulations of the PRC.

This site is not intended for use by children under the age of 14. We do not knowingly collect Personal Information from children under the age of 14. If we learn that we have collected Personal Information from a child under the age of 14, we will delete that data from our systems.

Our Sites may contain links to other sites for your convenience and information. If you access those links, you will leave our Sites. Allegis Group does not control those sites or their privacy practices, which may differ from Allegis Group's practices. Allegis Group is not responsible for the privacy practices or the content of other websites outside of Allegis Group. The Personal Information you choose to provide or that is collected by these third parties is not covered by this Notice. We encourage you to review the policies of such third parties before submitting your Personal Information.

Allegis Group may make message boards, news groups, and/or public forums available to users on its Sites. Any information that you disclose in these areas becomes public information that may be accessed by third parties; therefore, you should use caution before deciding to disclose any Personal Information in these forums.

If you wish to make a complaint about our handling of your Personal Information or an alleged breach of the privacy principles under applicable law, please complete the web form here . You will need to provide us with sufficient details regarding your complaint as well as any supporting evidence and/or information.

We will refer your complaint to our Privacy Officer who will investigate the issue within a reasonable time frame, which is usually 30 days but may be longer if the matter is complex. Our Privacy Officer will determine the steps (if any) that we will undertake to resolve your complaint. Such steps may include discussing the options for resolving the complaint with you, notifying relevant employees the subject of a complaint and seeking their input or escalation.

We will contact you if we require any additional information from you and will notify you in writing of the outcome of our investigation.

If you have any questions, please contact:

Allegis Group, Inc. 

APAC Headquarters

Level 18, Cambridge House

Taikoo Place, 979 Kings Road

Quarry Bay, Hong Kong

ATTN: Privacy Officer

APAC.Privacy@allegisgroup.com

If we change this Notice, we will post the revised Notice on our Sites, with an updated revision date. Any new Notice will automatically be effective when it is published on the website. You should therefore return here regularly to view our most up-to-date Notice. If we make material changes to our Notice, we may also notify you by other means, such as sending an email or posting a notice on our home page. The Effective Date of this Privacy Notice is December 1, 2023.