We at Nikkei China (Hong Kong) Ltd. take our responsibilities under the applicable laws and regulations relating to personal data protection (the “LAWS”) seriously. We also recognize the importance of the personal data you have entrusted to us and believe that it is our responsibility to properly manage, protect and process your personal data.

This Data Protection Policy is designed to assist you in understanding how we collect, use, store, disclose or in any other way process the personal data you have provided to us, as well as to assist you in making an informed decision before providing us with any of your personal data.

If you, at any time, have any queries on this policy or any other queries in relation to how we may manage, protect and/or process your personal data, please do not hesitate to contact our Data Protection Officer (the “DPO”) at: [email protected]

1. INTRODUCTION

1.1 “Personal Data” is defined under the LAWS to mean data, whether true or not, about an individual who can be directly or indirectly identified from that data, or from that data and other information to which an organization has or is likely to have access. Common examples of personal data could include names, identification numbers, contact information, medical records, photographs and video images.

1.2 We will collect your personal data in accordance with the LAWS. In general, before we collect any personal data from you, we will notify you of the purposes for which your personal data may be collected, used and/or disclosed, as well as obtain your consent for the collection, use and/or disclosure of your personal data for the intended purposes.

1.3 Your personal data may also be collected, used or disclosed if we have assessed that to do so would be in our legitimate interests and beneficial to the public. Before doing so, we will endeavour to ensure that any adverse effects that might arise for you have already been identified and eliminated, reduced or mitigated to the extent practicable.

2. PURPOSES FOR COLLECTION, USE & DISCLOSURE OF PERSONAL DATA

2.1 The personal data which we collect from you may be collected, used and/or disclosed for the following purposes:

1. (a) Registering and managing your subscription with us;
2. (b) Delivering the newspapers / magazines / publications to you according to the terms of your subscription with us;
3. (c) Collecting the subscription fees;
4. (d) Identity verification on making inquiries;
5. (e) Subject to your consent, contacting you for direct marketing activities including to introduce items such as publications and events such as seminars and exhibitions;
6. (f) Questionnaires and surveys for marketing; and
7. (g) Any purposes directly related to the purposes referred above.

(collectively, the “Purposes”)

2.2 In order to conduct our business operations more smoothly, we may also be disclosing the personal data you have provided to us to our third party service providers, agents and/or affiliates or related corporations, which may be sited either within or outside of Hong Kong or Mainland China, for one or more of the above-stated Purposes. This is because such third party service providers, agents and/or affiliates or related corporations would be processing your personal data on our behalf for one or more of the above-stated Purposes.

2.3 IWhen collecting your personal data, we will notify you whether it is obligatory or voluntary to supply certain data. If you fail to provide such data that is mandatorily required, we may not be able to provide you the services you request from us.

3. SPECIFIC ISSUES FOR THE DISCLOSURE OF PERSONAL DATA TO THIRD PARTIES

3.1 We respect the confidentiality of the personal data you have provided to us.

3.2 In that regard, we will not disclose any of your personal data to any third parties without first obtaining your express consent permitting us to do so. However, please note that we may disclose your personal data to third parties without first obtaining your consent to the extent permitted by LAWS in certain situations, including, without limitation, the following:

1. (a) cases in which the disclosure is required based on the applicable laws and/or regulations;
2. (b) cases in which the purpose of such disclosure is clearly in your interests, and if consent cannot be obtained in a timely way provided that we shall, as soon as may be practicable, notify you of the disclosure and the purposes of the disclosure;
3. (c) cases in which the disclosure is necessary to respond to an emergency that threatens the life, health or safety of yourself or another individual provided that we shall notify you of the purposes of the disclosure after the elimination of the emergency;
4. (d) cases in which there are reasonable grounds to believe that the health or safety of yourself or another individual will be seriously affected and consent for the disclosure of the data cannot be obtained in a timely way, provided that we shall, as soon as may be practicable, notify you of the disclosure and the purposes of the disclosure;
5. (e) cases in which the disclosure is necessary for any investigation or proceedings;
6. (f) cases in which the personal data is disclosed to any officer of a prescribed law enforcement agency, upon production of written authorisation signed by the head or director of that law enforcement agency or a person of a similar rank, certifying that the personal data is necessary for the purposes of the functions or duties of the officer; and/or
7. (g) cases in which the disclosure is to a public agency and such disclosure is necessary in the public interest.

3.3 The instances listed above at paragraph 3.2 are not intended to be exhaustive. We may disclose or use your personal data without obtaining your express consent in those exempted instances specified by LAWS, including those specified under Part 8 of the Personal Data (Privacy) Ordinance of Hong Kong (“PDPO”) or Article 13 of the Personal Information Protection Law of the People's Republic of China (“PIPL”).

3.4 In all other instances of disclosure of personal data to third parties with your express consent, we will endeavour to provide adequate supervision over the handling and administration of your personal data by such third parties, as well as to provide for adequate forms of protection over such personal data.

3.5 Where personal data is transferred by us to any third parties outside of Hong Kong or Mainland China, we will ensure that such transfers are compliant with the requirements under the PDPO or PIPL, as the case may be. In this regard, we will take such necessary measures to ensure that such overseas recipients are bound by legally enforceable obligations to ensure that these overseas recipients provide a standard of protection to the personal data so transferred that is comparable to the protection under the PDPO or PIPL, if required by law.

4. REQUEST FOR ACCESS AND/OR CORRECTION OF PERSONAL DATA

4.1 You may request to access and/or correct the personal data currently in our possession at any time by submitting your request through the following methods:
E-mail: [email protected] (Attention to the ‘Data Protection Officer’)

4.2 For a request to access personal data, we will seek to provide you with the relevant personal data within 40 days upon receipt of such request. Where we are unable to respond to you within the said period, we will notify you of the reason why we are not able to do so. Please also note that the LAWS exempts certain types of personal data from being subject to your access request.

4.3 For a request to correct personal data, we will undertake the following:

1. (a) we will correct your personal data (if any) within 40 days upon receipt of the request. Where we are unable to do so within the said period, we will notify you of the reason why we are not able to do so. Please note that the LAWS exempts certain types of personal data from being subject to your correction request as well as provides for situation(s) when correction need not be made by us despite your request; and
2. (b) subject to paragraph 4.4 and to the extent permitted by LAWS, we will send the corrected personal data to such third parties to which the personal data was disclosed by us within a year before the date the correction was made, unless that we have reason to believe that the third party has ceased using the data for the purpose (including any directly related purpose) for which the data was disclosed to the third party.

4.4 Notwithstanding paragraph 4.3(b), we may send the corrected personal data only to specific third parties to which the personal data was disclosed by us within a year before the date the correction was made.

4.5 Depending on the nature of the work required to process your access request, we may be required to charge you a reasonable fee for the handling and processing of your requests to access your personal data to recover administrative costs. Our Data Protection Officer will determine whether such a fee should be imposed on a case-by-case basis. Where such a fee is to be imposed, we shall provide you with a written estimate of the fee for your consideration. We shall only begin processing your access request upon receiving your agreement to the payment of the fee.

4.6 Your close relatives may, in accordance with PIPL (where applicable) and for the purpose of their lawful and legitimate interests, make requests to access, copy, correct and delete your personal information after you pass away. If you wish to make any special arrangement on this, you may contact us by email: [email protected]

5. REQUEST TO WITHDRAW CONSENT

5.1 You may withdraw your consent for the collection, use, process and/or disclosure of your personal data in our possession or under our control at any time by submitting your request through the following methods:
E-mail : [email protected] (Attention to the 'Data Protection Officer')

5.2 Please note that we may require 10 business days to process your request and to give effect to the withdrawal, and will thereafter refrain from collecting, using, processing and/or disclosing your personal data in the manner stated in your request.

5.3 However, if you choose to withdraw your consent, we may not be able to fulfil the purposes for which we require the personal data, including for us to contact you or to provide some or all of the products or services which you may need from us.

6. ADMINISTRATION AND MANAGEMENT OF PERSONAL DATA

6.1 We will take appropriate measures to keep your personal data accurate, complete and updated.

6.2 We will also take commercially reasonable efforts to take appropriate precautions and preventive measures to ensure that your personal data is adequately protected and secured. Appropriate security arrangements will be taken to prevent any unauthorized access, collection, use, disclosure, copying, modification, processing, erasure, transmission, leakage, loss, damage and/or alteration of your personal data. Staff members, agents, contractors and third-party service providers designated to handle personal data will be instructed to do so only in accordance with this policy and LAWS. However, we cannot assume responsibility for any unauthorized use of your personal data by third parties which are wholly attributable to factors beyond our control.

6.3 We will also take commercially reasonably efforts to ensure that the personal data in our possession or under our control is destroyed and/or anonymized as soon as it is reasonable to assume that (i) the purpose for which that personal data was collected is no longer being served by the retention of such personal data; and (ii) retention is no longer necessary for any other legal or business purposes.

7. ENQUIRY OR COMPLAINT

7.1 If you have any enquiry, complaint or grievance regarding about how we are handling your personal data or about how we are complying with the LAWS, we welcome you to contact us with your enquiry, complaint or grievance.

7.2 Please contact us through one of the following methods with your enquiry, complaint or grievance:
E-mail: [email protected] (Attention it to the ‘Data Protection Officer’.)

7.3 Where it is an email through which you are submitting a complaint, your indication at the subject header that it is a complaint regarding Personal Data would assist us in attending to your complaint speedily by passing it on to the relevant staff in our company to handle. For example, you could insert the subject header as “Personal Data Complaint”.

7.4 We will certainly strive to deal with any enquiry, complaint or grievance that you may have speedily and fairly.

8. UPDATES ON DATA PROTECTION POLICY

8.1 As part of our efforts to ensure that we properly manage, protect and process your personal data, we will be reviewing our policies, procedures and processes from time to time.

8.2 We reserve the right to amend the terms of this Data Protection Policy at our absolute discretion. Any amended Data Protection Policy will be posted on our website and can be viewed at https://www.nikkeiasia.com/en/policy/index_china.html. We will notify you of the updates and where necessary, obtain your consent if substantial changes are involved.

8.3 You are encouraged to visit the above website from time to time to ensure that you are well informed of our latest policies in relation to personal data protection.

Copyright Policy

All text and graphic material on this site is copyrighted and may not be resold or reproduced without the written permission of Nikkei Inc., or Nikkei China (HK) Ltd. The information here is accurate to the best of our knowledge at the time of issue. We do not, however, make any such guarantees or warranties to that effect, nor do we accept any responsibility for any damage whatsoever arising from the use of this service. We are happy to permit links to be made to our site but we prefer that you link to the front page address https://www.nikkeiasia.com/, not directly to other pages. We reserve the right to change these terms and conditions at any time. If you are a first-time visitor, you should take some time to look at the help section and become familiar with the structure of this site.