Privacy Policy
Privacy Policy
neueHCT understands the importance of your personal information and will do its utmost to protect its security. This Privacy Policy ("this Policy") is crucial when you use our official website. In this Policy, we will describe in detail our activities regarding the collection, use, sharing, transfer, storage, public disclosure, and protection of your personal information when you use our official website. Therefore, we hope you will read and fully understand this Policy carefully. We have highlighted clauses that may have a significant impact on your rights using bold text, so please pay special attention to them.
Before using our official website, you need to carefully read and fully understand this policy to determine whether you agree to its contents. Your use or continued use of our official website (including but not limited to actively providing us with your personal information) signifies your agreement to this policy and your authorization for us to collect, use, share, transfer, store, publicly disclose, and protect your information in accordance with this policy. If you do not agree to this policy, please immediately stop using the services we provide and avoid providing us with your personal information.
If you do not have full civil capacity, please carefully read and fully understand this policy under the supervision of your guardian, and ensure that you use our official website or provide us with your personal information only after obtaining your guardian's explicit consent. If the information you provide contains the personal information of others, you must ensure that you have obtained legal and sufficient authorization before providing us with such personal information.
This policy will help you understand the following:
Introduction to relevant concepts and the scope of this policy
How we collect and use your personal information
How we share, transfer, and disclose your personal information
Your rights
How we store and protect your personal information
How we handle the personal information of minors
How we use cookies and similar technologies
Revisions and updates to this policy
Contact information
Other
Introduction to Relevant Concepts and Scope of Application of this Policy
1.1 Introduction to Concepts
(a) Personal Information: Information recorded electronically or otherwise relating to an identified or identifiable natural person, excluding anonymized information, including but not limited to name, date of birth, ID number, personal biometric information, address, contact information, communication records and content, account passwords, property information, credit information, whereabouts, accommodation information, health and physiological information, transaction information, etc.
(b) Our Services: Refers to all products or services we provide to you through the neueHCT official website https://www.horizon-continental.com/
(c) De-identification: The process by which personal information is processed to make it impossible to identify a specific natural person without additional information. De-identification is based on the individual, retaining individual granularity, and using techniques such as pseudonyms, encryption, and hash functions to replace the identification of personal information.
(d) Anonymization: The process by which personal information is processed to make it impossible to identify a specific natural person and cannot be restored. Information obtained after anonymizing personal information is not considered personal information.
(e) Express Consent: The data subject actively authorizes the specific processing of their personal information by making a written, oral, or electronic statement, or by taking an affirmative action. Affirmative actions include the data subject actively checking or clicking "Agree," "Register," "Send," "Call," or actively filling in or providing information.
(f) Deletion: The act of removing personal information from systems involved in daily business functions, rendering it unsearchable and inaccessible.
1.2 Scope of Application This policy applies to the general rules regarding the processing of your personal information when you use our services. Please note that this policy does not apply to products or services (if any) provided to you by other third parties; such products or services are subject to the privacy policies explained to you by those third parties.
2 How We Collect and Use Your Personal Information
2.1 Collection and Use of Personal Information
Here, we truthfully and clearly inform you of the purpose, type, and use of the personal information we collect when you use our services:
(a) Submitting a Resume
When you submit your resume to us, you need to provide neueHCT with your name, contact information, resume, and message. We collect your name and contact information to verify your identity and for subsequent communication, including but not limited to informing you of interview arrangements or recruitment progress. We collect your resume, including your personal background, education, work experience, etc., to help us evaluate your eligibility for the position. You can choose to leave us a message to help us understand your job intentions and personal circumstances.
(b) Contacting Us
When you contact us by leaving us a message, you need to provide neueHCT with your name, province & city, phone number, email address, and message content. We collect your name, phone number, and message content to verify your identity, help us understand your needs or questions, and facilitate us to contact you directly when necessary to answer your questions or provide service support. You can choose to provide us with your province & city to help us understand your geographical location so that we can provide more targeted services or support. You may choose to provide us with your email address so we can contact you via email, send relevant information, or respond to your inquiries.
2.2 You understand and agree that, in order to optimize your user experience, we may further optimize our technology while improving and/or launching new services. This may involve adjustments to the content, method, or purpose of collecting personal information. We will separately explain any changes related to the collection and use of personal information to you through updates to this policy, system announcements, etc. If you have any questions during this process, you can contact us using the contact information listed in Article 9, and we will provide you with answers within 15 business days. Exceptions
In accordance with laws, regulations, and relevant national standards, we may collect and use your personal information without your authorization or consent in the following circumstances:
(i) Related to our fulfillment of obligations stipulated by laws and regulations;
(ii) Necessary for responding to public health emergencies or protecting the life, health, and property safety of natural persons in emergency situations;
(iii) Processing personal information within a reasonable scope for news reporting, public opinion supervision, and other activities for the public interest;
(iv) Processing personal information that individuals have voluntarily disclosed or that has been legally disclosed within a reasonable scope in accordance with the provisions of the Personal Information Protection Law;
(v) Necessary for signing and performing contracts at your request, or necessary for implementing human resource management in accordance with legally established labor rules and regulations and legally signed collective contracts;
(vi) Other circumstances stipulated by laws and administrative regulations.
How We Share, Transfer, and Disclose Your Personal Information
3.1 Sharing
We will not share your personal information with any other company, organization, or individual, except in the following circumstances:
(i) Sharing with explicit consent: We will share your personal information with other parties after obtaining your explicit consent;
(ii) Sharing under statutory circumstances: We may share your personal information as required by applicable law for resolving litigation disputes, or as required by the statutory requirements of administrative, judicial, supervisory, or procuratorial authorities (including but not limited to regulatory agencies or other authorities of us or any affiliated companies, or organizations or individuals designated by such regulatory agencies or authorities);
(iii) As required or permitted by laws and regulations, and as necessary to protect the rights and interests of us, other third parties, or the general public from harm.
3.2 Transfer
We will not transfer your personal information to any other company, organization, or individual, except in the following circumstances:
(i) With explicit consent: We will transfer your personal information to other parties after obtaining your explicit consent;
(ii) Under statutory circumstances: We may transfer your personal information in accordance with laws and regulations or statutory requirements of administrative, judicial, supervisory, or procuratorial authorities (including but not limited to regulatory agencies or other authorities of us or any affiliated companies, or organizations or individuals designated by such regulatory agencies or authorities);
(iii) In the event of a merger, acquisition, or bankruptcy liquidation: If the transfer of personal information is involved, we will inform you of the name or name and contact information of the recipient, and will require the company or organization that subsequently holds your personal information to continue to be bound by this policy; otherwise, we will require the company or organization to obtain your authorization and consent again.
3.3 Public Disclosure
We will only publicly disclose your personal information in the following circumstances:
(i) With your explicit consent;
(ii) Disclosure based on law: We may publicly disclose your personal information when required by law, legal process, litigation, or mandatory requirements of government authorities (including but not limited to regulatory agencies or other authorities of us or any affiliated companies, or organizations or individuals designated by such regulatory agencies or authorities).
3.4 Exceptions
We may share, transfer, or publicly disclose your personal information without obtaining your authorization or consent in the following circumstances:
(i) Related to your fulfillment of obligations stipulated by laws and regulations;
(ii) Related to national security or defense security;
(iii) Related to public safety, public health, or major public interests;
(iv) Related to criminal investigation, prosecution, trial, and execution of judgments;
(v) Necessary to protect your or other individuals' life, property, or other significant legitimate rights and interests, but obtaining your authorization or consent is difficult;
(vi) Personal information that you have voluntarily disclosed to the public;
(vii) Personal information collected from legally publicly disclosed information, such as legitimate news reports or government information disclosure channels;
(viii) Related to our fulfillment of obligations stipulated by laws and regulations.
According to the Personal Information Protection Law, personal information that has been anonymized and cannot identify a specific natural person and cannot be restored is not considered personal information. We will not need to notify you separately or obtain your consent for the sharing, transfer, and public disclosure of such information.
Your Rights
In accordance with relevant Chinese laws, regulations, and standards, as well as common practices in other countries and regions, we guarantee your right to exercise the following rights regarding your personal information:
4.1 Access and Modification of Your Personal Information
You have the right to access and modify your personal information. You can contact us through the contact information specified in Article 9 of this Agreement to access and modify your personal information. We will respond to your access or modification request within 15 business days.
4.2 Deletion of Your Personal Information
You may request that we delete your personal information in the following circumstances:
(i) If our processing of personal information violates laws and regulations;
(ii) If we collect or use your personal information without your consent;
(iii) If our processing of personal information violates our agreement with you;
(iv) If you no longer use our services;
(v) If the purpose of processing has been achieved, cannot be achieved, or is no longer necessary to achieve the purpose of processing;
(vi) If we no longer provide services to you, or the retention period has expired;
(vii) If you withdraw your consent;
(viii) Other circumstances stipulated by laws and administrative regulations.
Once we decide to respond to your deletion request, we will immediately remove your personal information from our systems. However, due to technical limitations, we may not be able to immediately delete the corresponding information from our backup systems. Nevertheless, we will ensure that the information in our backup systems is not reused for routine business or other purposes, and that this information is promptly deleted when backups are updated.
4.3 Withdrawal of Your Authorization and Consent
You have the right to withdraw your authorization, but each business function requires some basic personal information to be completed. When a service relies on your personal information to function or operate normally, if you withdraw your authorization, we will be unable to continue providing the corresponding service or some functions of that service will be affected.
You can contact us through the contact information specified in Section 9 of this policy to withdraw your authorization for certain personal information. We will respond to your request within 15 business days. Once you withdraw your authorization, we will no longer process the corresponding personal information. However, your decision to withdraw your authorization will not affect the processing of personal information previously carried out based on your authorization.
4.4 Obtaining a Copy of Your Personal Information
You have the right to obtain a copy of your personal information. You can contact us through the contact information specified in this policy. We will respond to your request within 15 business days.
4.5 Restraining Automated Decision-Making by Information Systems
In some business functions, we may make decisions solely based on non-human automated decision-making mechanisms, including information systems and algorithms. If these decisions significantly affect your legitimate rights and interests, you have the right to request an explanation from us, and we will also provide appropriate remedies.
4.6 Responding to Your Requests
For security reasons, you may need to provide a written request or otherwise prove your identity. We may require you to verify your identity before processing your request. We will respond within the timeframe stipulated by laws, regulations, or this policy.
In principle, we do not charge fees for reasonable requests. However, for repeated requests that exceed reasonable limits, we will charge a certain cost fee as appropriate. We may refuse requests that are unreasonably repetitive, require excessive technical means (e.g., require the development of new systems or fundamental changes to current practices), pose risks to the legitimate rights and interests of others, or are highly impractical.
We will be unable to respond to your request in the following circumstances:
(i) It relates to our fulfillment of obligations stipulated by laws and regulations;
(ii) It is directly related to national security or defense security;
(iii) It is directly related to public safety, public health, or major public interests;
(iv) It is directly related to criminal investigation, prosecution, trial, and execution of judgments;
(v) We have sufficient evidence to show that you have acted maliciously or abused your rights;
(vi) It is necessary to protect your or other individuals' life, property, or other major legitimate rights and interests, but it is difficult to obtain your authorization and consent;
(vii) Responding to your request would seriously harm the legitimate rights and interests of you or other individuals or organizations;
(viii) It involves trade secrets.
If we decide not to respond to your request, we will inform you of the decision and the reasons for it. You can contact us and file a complaint through the contact information provided in this policy.
How We Store and Protect Your Personal Information
5.1 How We Store Your Personal Information
We retain your information only for the period necessary for the purposes described in this policy and within the time limits required by laws and regulations.
(a) Storage Location: Information collected and generated during our operations within the People's Republic of China is stored within China. Currently, we do not have any scenarios involving cross-border transfer of your personal information or provision of personal information to overseas entities. If cross-border storage or provision of personal information to overseas entities is required, we will separately and clearly inform you and obtain your authorization and consent again, and strictly require the recipient to process your personal information in accordance with this policy and relevant laws and regulations.
(b) Storage Time: In principle, if you authorize us to store your personal information during your use of our services, we will store your personal information for the shortest time necessary to achieve the purpose for which you have authorized its use; after the above-mentioned personal information storage period, we will delete or anonymize the personal information. If there are other mandatory provisions in laws and regulations, we will handle them in accordance with the mandatory provisions.
5.2 Protection of Your Personal Information
(a) Technical Protection: We will use reasonable and feasible means such as encryption technology and anonymization processing that are no less advanced than those used by our industry peers to protect your personal information, and use security protection mechanisms to prevent your personal information from being maliciously attacked.
(b) Institutional Protection: We will establish a dedicated security department, security management system, and data security procedures to protect the security of your personal information. We adopt strict data usage and access systems to ensure that only authorized personnel can access your personal information, and we will conduct security audits of data and technology as needed.
(c) Written Restrictions on Partners: Before sharing your personal information with our business partners, we will strictly require them to fulfill their information protection obligations and responsibilities. We will require them to sign a data security protection agreement before cooperation. If any third party or our business partner breaches this agreement, they will bear corresponding legal responsibility.
(d) Handling Information Security Incidents: To address potential risks such as leakage, damage, and loss of personal information, we will promptly inform you, in accordance with legal requirements, of: the basic situation and potential impact of the security incident, the measures we have taken or will take, suggestions for you to prevent and mitigate risks, and remedial measures for you. We will also promptly inform you of the relevant circumstances of the incident via email, letter, telephone, push notification, etc. When it is difficult to notify each individual data subject, we will take reasonable and effective measures to issue a public announcement. Furthermore, we will proactively report the handling of personal information security incidents as required by regulatory authorities.
(e) Despite having taken the above reasonable and effective measures and complied with the standards required by relevant laws and regulations, please understand that the internet environment is not 100% secure. We will do our best to ensure the security of the personal information you provide to us. If our physical, technical, or administrative safeguards are breached, resulting in unauthorized access, public disclosure, alteration, or destruction of your information, and causing damage to your legitimate rights and interests, we will bear corresponding legal responsibility. Unless otherwise stipulated by laws and regulations, our liability will be limited to the direct losses caused to you.
How We Handle the Personal Information of Minors
Our services are primarily intended for adults. If you are a minor under the age of 18, you should read this policy with the assistance of your parent or guardian before using our services, and ensure that you have obtained your guardian's consent before using our services and providing us with your information. If your guardian does not agree to your use of our services or provision of information to us in accordance with this policy, please immediately stop using our services. For cases where personal information of minors is collected with parental consent, we will only use or disclose this information as permitted by law, with the explicit consent of the parent or guardian, or as necessary to protect the minor.
If we discover that personal information of a minor has been collected without prior consent from their parent or guardian, we will endeavor to delete the relevant data as soon as possible.
How We Use Cookies and Similar Technologies
To ensure the proper operation of our services, we will store small data files called cookies on your computer or mobile device. Cookies typically contain identifiers, site names, and some numbers and characters. We will not use cookies for any purpose other than those described in our Cookies Policy. For details regarding our use of cookies and similar technologies and how they process your personal data, please see our Cookies Policy: https://www.horizon-continental.com/cookies.
Revision and Update of this Policy
We will update the terms of this policy in accordance with service updates and relevant legal and regulatory requirements. Such updates constitute part of this policy, and we will notify you through system announcements or other appropriate means before the revisions take effect. In such cases, your continued use of our services constitutes your agreement to be bound by the revised policy. We will not restrict your rights under this policy without your explicit consent.
For significant changes, we will also provide more prominent notifications (including notifications through system announcements or pop-up or email alerts).
Significant changes referred to in this policy include, but are not limited to:
(i) Significant changes to our service model, such as the purpose of processing personal information, the types of personal information processed, and the ways in which personal information is used;
(ii) Significant changes to our control, etc. Such changes include:
(iii) Changes in the primary recipients of shared, transferred, or publicly disclosed personal information;
(iv) Significant changes in your rights regarding personal information processing and how to exercise them;
(v) Changes in the department responsible for personal information security, contact information, and complaint channels;
(vi) When a personal information security impact assessment report indicates a high risk;
(vii) Other significant circumstances that may seriously affect your personal rights.
We will indicate the date of each update and archive the document prior to the update for you. You can contact us at any time using the contact information provided in Section 9 of this policy if you require access to these documents.
9. Contact Information
If you have any questions, comments, or suggestions regarding this policy, or if you have any needs regarding the withdrawal, deletion, access, modification, or protection of your personal information, or any disputes, complaints, or reports related to personal information security, you may contact us at any time through the following methods:
neueHCT
Address: No. 2, Lane 150, Taiye Street, Jiading District, Shanghai
Email: marketing@horizon-continental.com
We will make every effort to provide you with a satisfactory solution and will process your request within 15 working days.
Other
The interpretation and dispute resolution of this policy shall be governed by the laws of the People's Republic of China. In the event of any dispute arising from the signing or performance of this policy, both parties shall endeavor to resolve it amicably through negotiation; if the negotiation fails, either party may file a lawsuit with the People's Court with jurisdiction in the defendant's place of residence.
