Personal Information Protection and Privacy Policy of JAJI
(March 2024 Edition)
This "Personal Information Protection and Privacy Policy" (hereinafter referred to as "the Policy") applies to activities related to the handling of your personal information by JAJI (Shanghai) Co., Ltd. (hereinafter referred to as "JAJI"). JAJI is fully aware of the importance of your personal information and will make every effort to protect its security. We are committed to maintaining your trust in us and adhering to the following principles to protect your personal information: consistency of rights and responsibilities, clarity of purpose, consent through choice, minimal necessity, ensuring security, subject participation, openness and transparency, among others. Additionally, JAJI promises to adopt corresponding security measures in accordance with mature industry standards to protect your personal information.
Please carefully read and understand this Policy before providing us with your personal information and/or using our products or services. This Policy will help you understand the following:
Section One: The Purpose of Handling of Your Personal Information (Purpose of Processing)
Section Two: How We Handle Your Personal Information (Methods of Processing)
Section Three: Protection of Your Personal Information
Section Four: Your Rights
Section Five: How We Handle Children's Personal Information
Section Six: How Your Personal Information Is Transferred Globally
Section Seven: How This Policy Is Updated
Section Eight: How to Contact Us
Section One: The Purpose of Handling of Your Personal Information (Purpose of Processing)
1. During the process of applying for job opportunities, seeking career advice, participating in training, handling onboarding procedures, and/or using our products or services such as mini-programs and apps on various platforms, we rely on the relevant personal information provided by you to accept your applications and/or provide you with relevant products and services. In such circumstances, our purpose in handling your personal information is to complete the aforementioned tasks.
2. We may also process your personal information for the purpose of entering into and fulfilling obligations under contracts where you are a party, implementing human resource management in accordance with legally established labor regulations, or fulfilling statutory duties or obligations.
Section Two: How We Handle Your Personal Information (Methods of Processing)
1. How We Collect Your Personal Information
During the process of applying for a job, seeking career advice, participating in training, handling onboarding procedures, and/or using our products or services such as mini-programs and apps on various platforms, you may voluntarily choose to provide us with or allow us to collect the following personal information through online and/or offline methods: [name, birthdate, gender, education level, degree, occupation, work experience, etc.]. The types of information involved include basic personal information, educational information, work information, and more. Additionally, you are aware that we may also collect personal information that you have publicly disclosed or is otherwise legally accessible for our processing purposes.
2. How We Store and Process Your Personal Information
a) If we collect your personal information through online platforms, we may store such information on those platforms and securely keep our account details and passwords.
b) If we retain paper documents containing your personal information, we will store them within our office premises and implement protective measures.
c) If we store your personal information on our internal computers and/or servers, we will securely keep the relevant account details and passwords.
d) We may need to perform general editing on your personal information, such as modifying, deleting, or adding, or categorize and compile multiple pieces of personal information.
3. How We Transmit, Provide, and Disclose Your Personal Information
a) You understand and agree that, for the purposes of our processing, we may transmit and provide your personal information through methods such as email:
i) Internally within JAJI;
ii) To our clients, after confirming that the recipient is a party to our business contract and that we are obligated to provide such personal information under the terms of the business contract;
iii) To our suppliers, after verifying that we have entered into a contract with the supplier, that the contract contains personal information protection clauses, and that the clauses specify the supplier's purpose, duration, manner, type, and protective measures for using the personal information.
b) Except in cases required by judicial authorities, government agencies, or when you request it, we will not disclose any of your personal information.
4. How We Delete Your Personal Information
If you request us to delete your personal information, withdraw your consent for us to process your personal information, or explicitly refuse us from processing any personal information that you have publicly disclosed or is otherwise legally accessible, we will promptly delete your corresponding personal information after verifying the relevant situation.
5. Commissioned Processing
For companies, organizations, and individuals whom we entrust to process personal information, we will sign strict confidentiality agreements with them, requiring them to handle personal information in accordance with our requirements, this policy, and any other relevant confidentiality and security measures.
6. Separate Consent
If any of the aforementioned scenarios do not fall under the categories where obtaining your consent is not legally required, such as fulfilling a contract with you or implementing legally mandated human resource management measures, and if the law explicitly requires separate consent from you, we will obtain your separate consent for such personal information processing activities.
Section Three. Protection of Your Personal Information
1. We adopt classified management measures for personal information stored in our internal specific systems. The classification management work categorizes personal information based on factors such as sensitivity and privacy level. We set access permissions for different categories of personal information for our internal processing personnel according to our work needs and management arrangements.
2. We have implemented security measures that comply with industry standards to protect the personal information you provide, preventing unauthorized access, disclosure, use, modification, damage, or loss of data. We take all reasonable and feasible measures to safeguard your personal information.
3. We take all reasonable and feasible measures to ensure that we do not collect irrelevant personal information. We only retain your personal information for the period necessary to achieve the processing purposes stated in this policy, unless there is a need to extend the retention period or it is permitted by law.
4. While the internet environment is not one hundred percent secure, we will do our utmost to ensure or guarantee the security of any information you send to us. If our physical, technical, or management safeguards are unfortunately compromised, resulting in unauthorized access, disclosure, tampering, destruction, or other personal information security incidents, we will promptly inform you in accordance with legal and regulatory requirements of the basic situation and potential impact of the security incident, the measures we have taken or will take, suggestions for you to independently prevent and mitigate risks, and remedial measures for you. We will promptly inform you of the relevant situation through emails, letters, phone calls, push notifications, etc. If it is difficult to inform individual data subjects one by one, we will take reasonable and effective measures to issue a public announcement. At the same time, we will actively report the handling of personal information security incidents to the regulatory authorities as required.
Section Four. Your Rights
1. Accessing and Copying Your Personal Information
For any personal information generated during your use of our products or services, or for any personal information that you have lost and cannot access anymore, we will provide it to you upon your request, insofar as it does not require excessive effort. In such cases, you may choose to access and/or copy such personal information.
2. Correcting and Supplementing Your Personal Information
If you find any errors and/or omissions in the personal information we process about you, you have the right to request corrections and/or supplements.
3. Deleting Your Personal Information
You can request the deletion of your personal information in the following circumstances:
a) If our processing of personal information violates laws and regulations;
b) If we process your personal information without your consent;
c) If you withdraw your consent for us to process your personal information;
d) If our processing of personal information violates our agreement with you;
e) If you no longer use our products or services;
f) If we no longer provide you with products or services.
If we decide to respond to your deletion request, we will also notify entities that have obtained your personal information from us to request the timely deletion of the same, unless otherwise stipulated by laws and regulations or these entities have obtained your independent authorization. When you actively delete information from the system (if any) that we provide products or services on, we may not immediately delete the corresponding information from our backup systems, but will delete it during the backup update.
4. Withdrawing Consent or Changing the Scope of Your Authorized Consent
You should understand that in order to accept your job applications and/or provide you with relevant products and services, we need to process your corresponding personal information. If you withdraw your consent or change the scope of your authorized consent, we will no longer process the corresponding personal information, which may result in our inability to accept your job applications and/or provide you with relevant products and services. However, your decision to withdraw or change your consent will not affect the legality of our previously conducted personal information processing activities.
5. Responding to Your Requests
1. If you need to exercise any of the above rights, you can contact us through the contact information listed in Article 8, and we will respond to your request as soon as possible. To ensure security, in some cases, we may require you to provide a written request or otherwise prove your identity. We may ask you to verify your identity before processing your request. We will provide a response within [30] days. If it is necessary to extend the aforementioned period due to practical needs, we will notify you beforehand and explain the reasons.
2. In principle, we do not charge a fee for your reasonable requests, but for repeated or excessive requests beyond reasonable limits, we may charge a certain cost as appropriate. We may refuse requests that are unreasonably repetitive, require excessive technical means (e.g., developing a new system or fundamentally changing existing practices), pose risks to the legitimate rights and interests of others, or are highly impractical.
3. We will be unable to respond to your request in the following circumstances:
a) Those related to our fulfillment of obligations prescribed by laws and regulations;
b) Those directly related to national security and defense security;
c) Those directly related to public safety, public health, and major public interests;
d) Those directly related to criminal investigation, prosecution, trial, and execution of judgments;
e) When we have sufficient evidence to show that you have subjective malice or abuse of rights;
f) When we need to safeguard your or other individuals' vital legitimate rights and interests such as life and property, but it is difficult to obtain your consent;
g) Responding to your request will cause serious harm to the legitimate rights and interests of you or other individuals or organizations;
h) Those involving trade secrets.
Section Five: How We Handle Children's Personal Information
1. Before submitting applications for job interviews, seeking career advice, participating in training, handling onboarding procedures, and/or using our products or services such as mini-programs and apps on various platforms, you should ensure that you are at least 18 years old. If you are not, please refrain from making applications or using our services. We cannot accept your application or provide you with any products or services.
2. In cases where we collect children's personal information with the consent of their parents, we will only process this information when it is legally permissible, explicitly agreed by the parents or guardians, or necessary for the protection of the child. We consider anyone under the age of 14 as a child.
3. If we discover that we have collected personal information of children without prior verifiable consent from their parents, we will seek to delete the relevant data as soon as possible.
Section Six: How Your Personal Information Is Transferred Globally
In principle, personal information collected and generated within the territory of the People's Republic of China will be stored within the territory. However, due to our global customer base, we also provide products or services through resources and servers located worldwide. This means that, with your authorized consent, your personal information may be transmitted to corresponding overseas jurisdictions or accessed from these jurisdictions. Such jurisdictions may have different data protection laws or may not have any relevant laws. In such cases, we will comply with the provisions of current and effective laws, regulations, and rules of our country, and complete the necessary security assessments, personal information protection certifications, contracts with overseas recipients, and personal information protection impact assessments for data exports, to ensure that your personal information receives sufficient and equivalent protection within the territory of the People's Republic of China.
Section Seven: How This Policy Is Updated
This policy may undergo changes in accordance with the promulgation, modification, or abolition of national laws and regulations. We will publish any changes to this policy on our website. For significant changes, we will also provide more prominent notifications.
Section Eight: How to Contact Us
If you have any questions, comments, or suggestions regarding this policy, you can contact us through the following channels:
Contact Number: +86 21 60963686
Email: contact@jajiglobal.com
Generally, we will respond within 30 days. If there is a need to extend the response period due to practical reasons, we will notify you beforehand and explain the reasons.
