1 Privacy Notice

1.1   Shanghai Orio Quest (we/us/our) is committed to safeguarding the privacy of our customers and users (you/your) who visit our website (the Website).  This privacy notice (the Privacy Notice) sets out our personal information collection and sharing practices for our website and is intended to inform you of the ways in which our Website collects personal information, the uses of that personal information and the ways in which we will share any personal information you choose to provide to us.

1.2   Further notices highlighting certain uses we wish to make of your personal information together with the ability to opt in or out of selected uses may also be provided when we collect personal information from you.

1.3   Our Website may contain links to other third-party websites. If you follow a link to any of those third-party websites, please note that they have their own privacy policies and that we do not accept any responsibility or liability for their policies or processing of your personal information. Please check these policies before you submit any personal information to such third-party websites.

1.4   This Privacy Notice covers the following areas:

(a) What personal information about you we collect

(b) How we use your personal information

(c) How we protect your personal information

(d) Contacting us & your rights to prevent marketing and to access and update your personal information

(f) How changes to this Privacy Notice will be made

2 Information we collect about you.

2.1   We will collect and process all or some of the following personal information about you:

(a) Information you provide to us ► personal information that you provide to us, such as when using the contact form or any subscription forms on our website, including your name, email address, and other contact details. If you choose to apply for a job at Lippincott and submit a job application via our careers site, we will collect information that you submit via our careers site. Please refer to the candidate privacy notice on our careers site for information on how we process this information.

(b) Our correspondence ► if you contact us, we will typically keep a record of that correspondence.

(c) Survey information ► if we ask you to complete surveys that we use for research purposes, we shall collect the information provided in the completed survey.

(d) Website and communication usage ► details of your visits to the Website and information collected through cookies and other tracking technologies including, but not limited to, your IP address and domain name, your browser version and operating system, traffic data, location data, web logs and other communication data, and the resources that you access.

3 How we use your personal information.

3.1   In this section, we set out the purposes for which we use personal information that we collect via our Website.

3.2   Please note that, in addition to the disclosures we have identified below, in some circumstances we will also disclose personal information to service providers, contractors, agents and affiliates of Lippincott that perform activities described in this notice on our behalf.

(a) To communicate effectively with you and conduct our business ► to conduct our business, including to respond to your queries, to otherwise communicate with you, or to carry out our obligations arising from any agreements entered into between you and us, which in some circumstances may include passing your data to third parties such as agents or contractors or to our advisors (e.g. legal, financial, business or other advisors).

(b) To provide you with marketing materials ► to provide you with updates and offers, where you have chosen to receive these. We may also use your information for marketing our own and our selected business partners’ products and services to you by post, email, SMS, phone and fax and, where required by law, we will ask for your consent at the time we collect your data to conduct any of these types of marketing. We will provide an option to unsubscribe or opt-out of further communication on any electronic marketing communication sent to you or you may opt out by contacting us as set out in paragraph 5.5 below.

(c) For research and development purposes ► to analyse your personal information in order to better understand your and our other clients’ services and marketing requirements and to better understand our business and develop our products and services.

(d) To monitor certain activities ► to monitor queries and transactions to ensure service quality, compliance with procedures and to combat fraud.

(e) To inform you of changes ► to notify you about changes to our services and products.

(f) To ensure Website content is relevant ► to ensure that content from our Website is presented in the most effective manner for you and for your device, which may include passing your data to business partners, suppliers and/or service providers.

(g) To re-organise or make changes to our business ► if we: (i) are subject to negotiations for the sale of our business or part thereof to a third party; (ii) are sold to a third party; or (iii) undergo a re-organisation, we may need to transfer some or all of your personal information to the relevant third party (or its advisors) as part of any due diligence process for the purpose of analysing any proposed sale or re-organisation. We may also need to transfer your personal information to that re-organised entity or third party after the sale or reorganisation for them to use for the same purposes as set out in this Privacy Notice.

(h) In connection with legal or regulatory obligations ► Subject to the obligations and requirements under Chinese law, we process your personal information to comply with our regulatory requirements or as part of dialogue with our regulators as applicable which may include disclosing your personal information to third parties, the court service, regulators and/or law enforcement agencies in connection with enquiries, proceedings or investigations by such parties or where compelled to do so. Where permitted, we will direct any such request to you or notify you before responding unless to do so would prejudice the prevention or detection of a crime.

4 Transmission, storage and security of your personal information

Security over the internet

4.1   No data transmission over the Internet or website can be guaranteed to be secure from intrusion. However, we maintain commercially reasonable physical, electronic and procedural safeguards to protect your personal information in accordance with data protection legislative requirements.

4.2   All information you provide to us is stored on our or our subcontractors’ secure servers, which may be outside of China, and accessed and used subject to our security policies and standards. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our Website, you are responsible for keeping this password confidential and for complying with any other security procedures that we notify you of. We ask you not to share a password with anyone.

Provision, transfer and disclosure of personal information

4.3   As part of a multinational group and for our legitimate business needs and the processing purposes identified in section 3 above, we may transfer personal information to affiliates within the Marsh McLennan group of companies, including Oliver Wyman Group affiliates, a list of whom can be found here (the Recipients).

Before we provide your personal information outside the territory of China, we will meet the applicable requirements of laws and regulations of China on cross-border transfer of personal information and will require overseas Recipients to protect your personal information at the levels not lower than those required by applicable laws and regulations of China

Except where required or permitted by law, we will not disclose your personal information to the public without seeking and obtaining your separate consent.

Storage limits

4.4   We will retain your personal information for as long as is necessary for the processing purpose(s) for which it was collected and any other permitted linked purpose (for example where we are required to retain personal information for longer than the purpose for which we originally collected it in order to comply with certain regulatory requirements). After the relevant purposes are realized, your information will be either irreversibly anonymised (and the anonymised information is retained) or securely destroyed in accordance with our internal retention policy.

5 Your rights & contacting us

Marketing

5.1   You have the right to ask us not to process your personal information for marketing purposes. You can exercise the right at any time by clicking the “unsubscribe” option on any electronic marketing communication sent to you or by contacting us as set out in paragraph 5.5 below.

Updating information

5.2   We will use reasonable endeavours to ensure that your personal information is accurate. In order to assist us with this, you should notify us of any changes to the personal information that you have provided to us by contacting us as set out in paragraph 5.5 below.

Your rights

5.3   Under certain conditions, you have the right:

(a) to be informed of our processing activities and to make decisions with respect to your personal information in accordance with applicable law;

(b) to consult and copy your personal information;

(c) to correct or supplement your personal information if the information we hold is inaccurate or incomplete (please see paragraph 5.2);

(d) to request us to delete 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;

(e) to object to direct marketing (including any profiling for such purposes);

(f) to refuse or restrict the processing of your personal information in accordance with applicable law;

(g) to request us to explain our processing rules for your personal information;

(h) to request us to transfer your personal information to the personal information handler you designate when the legal conditions for such transfer are satisfied;

(i) 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;

and where processing is based on consent, you have the right to withdraw your consent by contacting us at the contact details in paragraph 5.5 below.

5.4   Your exercise of these rights is subject to certain exemptions and limitations required or permitted by law and a reasonable fee may be charged (where permitted under applicable laws). If you exercise any of these rights we will check your entitlement and respond in most cases within a month.

Contacting us

5.5   If you wish to exercise your rights in relation to your personal information with us or the Recipient(s), please email PRCDSRSubmissions@oliverwyman.com. If you have any questions in relation to this Privacy Notice, please email marketing@lippincott.com.

6 Changes to our Privacy Notice

6.1   We may change the content of our Website and consequently our Privacy Notice may change from time to time in the future. If we change this Privacy Notice, we will update the date the Privacy Notice was last changed below. If these changes are material, we will take reasonable steps to notify you of the changes and seek for your consent if required by applicable law.