PRIVACY POLICY
November 1, 2024
Keppel Yongda Commercial Management (Shanghai) Co., Ltd. and other related entities of Keppel China (hereinafter referred to as "Keppel China" or "we") highly value the protection of your personal information. This Privacy Policy (hereinafter referred to as "this Policy") is formulated in accordance with relevant laws, regulations, and standards of China. It aims to clarify how we collect, process, and protect your personal information, as well as how you can maintain your legal rights.
This Policy will help you understand the following:
1. How we collect and use your personal information
2. How we use cookies and other similar technologies
3. How we store your personal information
4. How we delegate processing, share, transfer, and disclose your personal information
5. How we protect your personal information
6. Your rights
7. How we handle children's personal information
8. How this Policy is updated
9. How to contact us
This Policy applies to our "Sindora Living Official Website" (the "Platform") and the products or services we provide to you. When you use our "Sindora Living Official Website" or accept our products or services, we may collect and use your relevant information through the "Sindora Living Official Website" as well as the forms, registration forms, and contracts (the "Documents") you fill out, sign, and submit.
Please read this Policy carefully and confirm that you fully understand its contents before providing your personal information. By following the guidelines in this Policy, you can make the choices you deem appropriate. We highlight sensitive information related to your personal data in bold italicized text to remind you to pay special attention.
Unless otherwise stated, your disagreement with this Policy or its updates (we will notify you of such updates in a timely manner) may affect your ability to use or continue using our Platform and/or services or to conduct business activities with us.
If you have any questions or concerns about this Policy or related matters, please contact us through the contact information provided in "9. How to Contact Us."
1. How We Collect and Use Your Personal Information
(A) Scenarios in Which We Collect and Use Your Personal Information
1. Information Registration
To make an appointment for consultation or a visit to our elderly care institution, we will collect your name, phone number, and city. These are required pieces of information for registration.
If you refuse to provide the required necessary information, you will not be able to complete the appointment or receive consultation. We collect this information to provide you with appointment scheduling, consultation, and other supplementary or value-added services, as well as to keep you informed about our products and services and those of our affiliated companies and partners.
2. Providing Our Products/Services
When you receive a membership gift, you need to provide us with your basic information, including [name, phone, and delivery address]. We collect this information to facilitate interconnection and coordination between service providers related to the services we provide.
3. Security and Management
To maintain public safety, we will install video surveillance systems in the public areas of the elderly care facilities. When you pass through these monitored areas, the system will record your personal image and activities, including facial recognition features. We will prominently indicate the presence of such surveillance systems and will only process the monitoring information within the limits allowed by law.
4. Providing a Better Service Experience
In order to provide you with a more comfortable service experience, we may collect the following personal information:
Log Information: When you use our products or services, we will automatically collect detailed usage information about your interaction with our services, such as your IP address, browser type, and network beacons.
5. Customer Service
When you contact our customer service, we need you to provide necessary personal information, including name, phone number, and city, to verify your identity and assist in addressing your issues.
6. Other Additional Services
To improve and enhance our services, we may gather your opinions or intentions through surveys or other marketing research activities, and may ask you to provide information such as name, gender, age, preferences, hobbies, etc. This may include health information (such as physical examination indicators), occupation details, and family situation. We collect this information for market research, planning, customer surveys, trend analysis, and/or other data analyses to provide you with customized offers, promotions, and/or other direct marketing.
Due to the variety of services we provide, we may collect your personal information in different scenarios based on actual business functions, and the information collected in one scenario may also be used in other scenarios.
(B) Exceptions to Obtaining Consent
Within the scope permitted by law, we may collect and use your personal information without obtaining your consent in the following situations, and we may not respond to your requests for correction, modification, deletion, cancellation, withdrawal of consent, or requests for information:
1. For entering into or performing contracts with you, or for implementing human resource management based on labor regulations or collective agreements.
2. For fulfilling legal duties or obligations.
3. For responding to public health emergencies, or in urgent situations to protect the life, health, and property safety of natural persons.
4. For news reporting, public opinion supervision, and other behaviors in the public interest, where personal information is processed within a reasonable scope.
5. To process personal information that has been publicly disclosed by you or legally disclosed, within a reasonable scope, excluding cases where it significantly affects your rights and interests.
6. Other situations stipulated by laws and administrative regulations.
2. How We Use Cookies and Other Similar Technologies
To provide you with a better experience and recommend content you may be interested in, we will use cookies, pixel tags/beacons, and scripts (collectively referred to as "Cookies"). With the help of cookies, we are able to store information about visits and visitors and analyze data to offer better services. By clicking "Agree" on the cookie notification, you agree to our use of cookies to provide services.
You can modify your acceptance of cookies or reject our cookies, but rejecting cookies may result in certain services relying on cookies being unavailable.
3. How We Store Your Personal Information
Your electronic personal information is stored on secure servers located within the People's Republic of China (excluding Hong Kong, Macau, and Taiwan) and is protected in controlled facilities. We classify your data based on importance and sensitivity and ensure the necessary security level for your personal information.
Non-electronic personal information, such as documents containing your personal information, will be stored in locked file cabinets and managed by designated personnel. We may also enter the collected non-electronic personal information into our system for electronic storage and protection.
If storage changes and your personal information is transferred overseas, we will strictly comply with legal and regulatory requirements to protect your personal information.
4. How We Delegate Processing, Share, Transfer, and Disclose Your Personal Information
(A) Delegated Processing
We may delegate external service providers to process your personal information to implement some of the services or features we provide. For example, certain features of the Platform may be provided by external service providers, and we may engage professional data processing service agencies to offer technical support for data analysis.
(B) Sharing
We usually do not share your personal information with other companies, organizations, or individuals, except in the following situations:
1. We may share your information with our affiliated companies. We will only share necessary information and will ensure that the processing is in line with the purposes outlined in this Policy.
2. We may share your personal information as required by laws, regulations, litigation, dispute resolution, or mandatory requests from administrative or judicial authorities. In such cases, we will inform you of such sharing, unless otherwise required by law or regulations.
(C) Transfer
We do not transfer your personal information to any third party, except in the following situations:
1. After obtaining your explicit consent, we may transfer your personal information to others.
2. In cases of mergers, acquisitions, dissolution, or bankruptcy liquidation, we will notify you of such transfer and ensure that the new holder of your personal information continues to be bound by this Policy.
(D) Public Disclosure
We only disclose your personal information in the following situations:
1. After obtaining your explicit consent;
2. Based on legal requirements: in cases of legal procedures, litigation, or mandatory requests from government departments, we may disclose your personal information.
5. How We Protect Your Personal Information
We attach great importance to the security of your personal information. For example, we assign designated personnel to store documents containing personal information and set internal mechanisms to prevent unauthorized access, extraction, or use. We use encryption, data desensitization, and other technologies to enhance the security of personal information and deploy access control mechanisms to prevent unauthorized access.
6. Your Rights
(A) Access to Your Personal Information
You can contact us through the information provided in "9. How to Contact Us" to inquire about the personal information we hold about you.
(B) Correction and Supplementation of Your Personal Information
If you find that the personal information we process is inaccurate or incomplete, you have the right to request correction or supplementation.
(C) Deletion of Your Personal Information
You can request the deletion of your personal information in the following situations:
1. If we process your personal information in violation of laws and regulations;
2. If we collect or use your personal information without your consent;
3. If you withdraw your consent after providing personal information;
4. If we process personal information in violation of agreements with you;
5. If you no longer use our products or services or have canceled your account;
6. If we no longer provide products or services to you;
7. If the processing purpose has been achieved or is no longer necessary.
(D) Changing or Withdrawing Your Consent
You can change the scope of your consent or withdraw your consent through settings or by contacting us.
(E) Obtaining a Copy of Your Personal Information
You may contact us to request a copy of your personal information or, under certain conditions, we can transmit your personal information to a third party of your choice.
7. How We Handle Children's Personal Information
Our platform, products, and services are primarily aimed at adults. Children may not create their own user accounts or access our services without the consent of their parents or guardians.
8. How This Policy is Updated
We may update this Policy periodically to adapt to legal, technological, or business developments. We will notify you of any major changes.
9. How to Contact Us
You can contact us at:
Email: informationSL@Keppel.com
DPO Email: cn.dpo@keppel.com