1.信息处理者及联络信息Responsible party and contact information
保赫曼（上海）贸易有限公司PAUL HARTMANN (Shanghai) Trade Co., Ltd.
个人信息保护负责联系人Contact Data Protection: 周巍蔚女士Ms. Ann Zhou
保赫曼（上海）贸易有限公司PAUL HARTMANN (Shanghai) Trade Co., Ltd.
部门Department: 合规部Compliance Dept.
2. 个人信息保护原则Data protection principles
We process your personal data in accordance with the provisions of the Personal Information Protection Law of People’s Republic of China（hereinafter refer to as “PIP Law” ）and other applicable data protection regulations. You will find details under the following explanations.
2.1 候选人资料Candidate profile
在申请空缺职位之前，有必要创建自己的候选人资料。 只有当您申请空缺职位时，我们才能看到此个人资料。 您可以随时自行更改或添加您的候选人资料。
Before applying for an open vacancy, it is necessary to create your own candidate profile. This profile will only be visible to us when you apply for an open vacancy. You can make changes or additions to your candidate profile yourself at any time.
Where it is necessary for the conclusion of a contract(cf. Art. 13(2) of PIP Law)
This data protection notice is issued in connection with the application procedure. Your personal data is processed in order to decide on the establishment of an employment relationship with you and to process it. This may also include the performance of an assessment, which especially may include the creation of a personality profile as part of a personality test. Although the evaluation of the personality test is initially automated, the content is then checked by the people involved in the recruitment process. The evaluation can then be included in the decision on whether to establish an employment relationship with you. As part of the application process, your personal data may also be viewed by employees of various specialist departments at national and international level, but only to the extent that this – as mentioned – serves to establish the employment relationship with you.
Where it is necessary for the implementation of human resources management in accordance with the labor rules and regulations formulated in accordance with the law and the collective contract concluded in accordance with the law; (cf. Art. 13(2) of PIP Law)
Statistical evaluations for corporate management;
Measures for controlling and optimizing business processes;
Measures for the further development of services and products;
Identification of recruited employees for distribution of bonus;
Testing and optimization of procedures for demand analysis;
Enrichment of our data, e.g. by using or researching publicly available data as far as necessary;
Active Sourcing (direct approach of candidates);
Benchmarking(especially comparison of the recruitment figures of the countries and the respective recruitment period. The benchmarking is anonymous);
Assertion of legal claims and defense in the event of legal disputes which are not directly attributable to the contractual relationship;
Building and plant security, securing and exercising of the right to the building by taking appropriate measures (e.g. access controls) and, if necessary, by video surveillance to protect third parties and our employees and to prevent criminal offences and to secure evidence for the investigation of criminal offences, insofar as this goes beyond the general duty of care;
Further development of existing systems and processes;
Internal and external investigations, security checks, publications;
Obtaining and maintaining certifications of a private or official nature.
Purposes within the scope of your consent (cf. Art. 13 (1) of PIP Law)
We process your personal data – in each case only based on your consent – for the following purposes:
Replacement of vacancies that have become vacant again, for which you originally applied, as well as for worldwide vacancies including inclusion in a talent pool to which PAUL HARTMANN AG Group companies have access at national and international level. In the last-mentioned case, we will contact you via the email address and/or phone number you have provided us with, if there is a corresponding open vacancy;
Messages in the form of "job alerts". The basis for these alerts is your application for a specific vacancy, in the context of which you have also created your candidate profile. The specific name of the open vacancy for which you have applied serves as a keyword. You can add or delete individual "job alerts" at any time;
•关于职业机会的消息。 如果您同时出现在我们的人才库中，您将被考虑参加由系统生成的定制营销活动。 此类营销活动可以参考当前的招聘会，例如，您可以获得有关职业机会的更多信息；
Messages about career opportunities. You will be considered for customized marketing campaigns – generated by the system – if you are visible in our talent pool at the same time. Such marketing campaigns can refer to current job fairs, for example, where you can get more information about career opportunities;
Active Sourcing - direct approach, addressed to you as a candidate.
您没有义务同意，并且您不会因拒绝同意而遭受任何法律上的不利影响。您可以随时撤回您的同意。原则上，任何时候撤回同意仅对将来有效。 撤回前进行的处理不受影响，因此仍然合法。 这意味着在撤销之前的一段时间内对您的个人信息的处理用于上述目的仍然有效。
You are not obliged to give your consent and there are no legal disadvantages for not granting your consent. You can withdraw your consent at any time in your career profile. In principle, the withdrawal of a consent is only effective for the future. Processing that took place before the withdrawal is not affected and remains lawful.
Purposes to meet legal requirements or purposes in the public interest (cf. Art. 13（3）（4）of PIP Law)
参与经济活动中，我们也承担着各种法律义务。 这些主要是法律要求以及适用的监管或其他官方要求（例如，社会保险和税法）。 此外，为了收集证据、刑事起诉或执行民事索赔，在官方/司法措施范围内可能需要披露个人信息。
Like everyone who is involved in the economic process, we are also subject to a variety of legal obligations. These are primarily legal requirements (e.g. Social Security and Tax laws). In addition, the disclosure of personal data may become necessary within the scope of official/judicial measures for the purpose of gathering evidence, criminal prosecution or the enforcement of civil law claims.
Categories and origin of the personal data we process
Insofar as it is necessary for the decision on the establishment of a contractual relationship with you, we process, in addition to the personal data received directly from you, any legally obtained personal data from third parties (see Art. 13（2）of PIP Law).
This may include personal data received from external service providers such as headhunters, professional network operators or social networks (e.g. LinkedIn ).
Relevant personal data might be:
First name and surname, gender, residential address, contact data, date of birth, place of birth, nationality, religious affiliation, marital status, job description, callable contact data, start / end of employment, educational background (school, studies, training etc.) and professional development, title, residence permit / work permit and its period of validity, data from identification document, qualifications (driver's license, first-aider, knowledge of foreign languages etc.) Status information (mainly pupil or student), information about certificates and qualifications, health conditions (e.g. for holiday entitlement or job description), honorary position / active membership in a club (sports etc.), information about previous employment relationships, criminal records (e.g. for security-relevant functions), photos, bank records (for travel expense accounting).
Recipients or categories of recipients of your personal data
We only process your personal data within the company. Within our company, those internal departments or organizational units receive your personal data insofar as they need it to fulfil the purpose and within the scope of processing. Internal data recipients are obliged in each case to use your personal data only to the aforementioned extent.
若我们将您的个人信息转移给其他人、公司或其他第三方（例如健康保险）或授予他们对个人信息的其他访问权限，只有在获得法律许可的情况下才会这样做。 如果我们委托第三方根据“处理协议”处理个人信息，会确保对个人信息的处理和使用具有必要的影响或控制权， 我们仍然处理数据的合法性对您负责。
If we transfer your personal data to other persons, companies or other third parties (e.g. public health insurance) or grant them other access to the personal data, this is only done on the basis of a legal permission. If we commission third parties to process personal data on the basis of a so-called "contract processing agreement" and thereby secure the necessary powers of influence or control with regard to the processing and use of the personal data, this is done on the basis of Art. 21 PIP Law. However, we remain responsible to you for the legality of the data processing.
Storage of your personal data, use of anonymized data
In principle, we process or store your personal data for the duration of the direct contact within the framework of active sourcing, for the duration of an active application process and for the duration of your activity in the candidate profile.
The above information on deletion does not apply if, among other things, legally prescribed retention periods prevent immediate deletion and/or a further case of Art. 13 of PIP law exists and/or a new purpose justifies further processing.
Incorrect and/or incomplete data will be deleted or - if possible - corrected immediately in accordance with Art.46,47 of PIP Law
First, we would like to point out that we may not delete your personal data but make it anonymous. After the anonymization process has been carried out, a reference to your person no longer exists and cannot be restored. The data protection regulations are then no longer applicable. We use the anonymized data in particular for evaluation purposes.
Your personal data in connection with a specific application will be made anonymous at the latest 6 months after the application process has been completed (beginning especially by refusal). If we only have your application documents in paper form, we will destroy or return them to you after the end of the application procedure to our credit.
The anonymization of your personal data stored in the candidate profile is done automatically in case of inactivity of 6 months (no login was made for 6 months). You will be informed about this in advance by email. By logging in again, the period is automatically extended by a further 6 months. The prerequisite in each case is that there is no active application. If you set up a "deletion" in your candidate profile yourself, the anonymization will take place automatically 6 months after setting up.
Exclusion anonymization, withdrawal
The above-mentioned information on the anonymization does not apply if, among other things, legally prescribed retention periods prevent immediate deletion – here anonymization – in accordance with Art. 13 of PIP law exists and/or a new purpose justifies further processing.
我们想指出，撤销您为上述第 2.4 条所述目的授予的同意仅具有让我们停止相应处理（例如发送“工作提醒”）的效果。 因此，撤销不会产生匿名化任何个人信息的效果。
We would like to point out that the withdrawal of a consent granted by you for the purposes mentioned in No. 2.4 above only has the effect that the respective processing (e.g. sending of "Job Alerts") is stopped by us. No personal data will therefore be anonymized by withdrawing.
6. 跨境处理您的个人信息Processing your personal data in a third country
Where possible, we will process your personal data on the territory of the People’s Republic of China. If, however, processing – and thus at the same time transfer – of your personal data to third countries is necessary, especially for the decision on the establishment of an employment relationship with you, we will ensure that the special legal requirements for such processing operations are met and that an adequate level of data protection prevails in the respective third country.
In particular, this includes conducting an impact assessment on personal information protection to protect your personal data.
7. 您的权利Your rights
You have the right to withdraw your consent to the processing of your personal data in accordance with Art.47 of PIP Law at any time with effect for the future. Processing that took place before the withdrawal therefore remains lawful.
In accordance with Art. 45 , you can request information about your personal data processed by us.
In accordance with Art. 46 of PIP Law, you can demand the immediate correction of incorrect or incomplete personal data stored by us.
In accordance with Art. 47 of PIP Law, you can request the deletion of your personal data stored by us in accordance with the conditions stated therein, unless legally prescribed retention periods prevent immediate deletion and/or another case of Art. 13 of PIP exists and/or a new purpose justifies further processing.
Pursuant to Art.47 of PIP Law , you may request the restriction of data processing where the storage period as stipulated by laws and administrative regulations does not expire, or the deletion of personal information is difficult to be realized technically in such case ,we will stop the processing other than storage and necessary security protection measures.
In accordance with Art. 45 of PIP Law, under the conditions stipulated by the CAC, you can request to transfer your personal information to a third processor, we will provide a way for the said transfer.
We would ask you to address any complaints first to us via the contact details given under 1. above. Where we refuse your request for exercising your rights, you may file a lawsuit with a people's court in accordance with the law.
Scope of your obligations to provide us with your personal information
You only need to provide personal data that is necessary for the decision on the establishment of the employment relationship or that we are legally obliged to collect (e.g. to provide evidence to authorities). Without this personal data, we will generally not be able to carry out the application process. If we request additional personal data from you, you will be informed separately about the voluntary nature of the information.
Automated decision making in individual cases (including profiling)
We do not use purely automated decision-making procedures in accordance with Art. 24. Should we nevertheless use such a procedure in individual cases in the future, we will inform you of this separately if this is required by law.
10. Cookie或同类技术 Cookie and Similar technologies
为提高我们的网络服务，我们会在您的计算机或移动设备上存储名为 Cookie 的小数据文件。Cookie 通常包含标识符、站点名称以及一些号码和字符。Cookie主要的功能是便于您使用网络平台产品和服务，以及帮助我们网络平台统计独立访客数量等。运用Cookie技术，我们能够为您提供更加周到的个性化服务，并允许您设定您特定的服务选项。
To improve our web service, we store small data files called cookies on your computer or mobile device. Cookies usually contain identifiers, site names, and some numbers and characters. The main function of cookies is to facilitate your use of our online platform products and services, and to help our online platform to count the number of individual visitors. Using cookie technology, we can provide you with more personalized services and allow you to set your specific service options.
当您使用本公司的产品和服务时，您同意我们使用Cookie或同类技术。Cookie 和其他技术用于为我们的网站服务提供某些功能，例如用户识别、用户预设的存储、向用户明确分配临时进程或交易相关数据、在您登录到用户帐户期间，存储附加安全信息或收集有关网站使用情况的信息，并改进网站设计和功能。几乎所有网站均使用这些技术来识别使用相同的终端设备和相同的浏览器访问过的用户，以便它们可以调整显示的内容，并在某些情况下进行相应的更改。 我们和我们第三方服务提供商也使用 Cookie 和其他技术。
您可以清除计算机上保存的所有 Cookie，大部分网络浏览器都设有阻止 Cookie 的功能。我们也可能增加按钮，让您确定是否同意在特定网络服务范围内同意使用Cookie 的功能。如果您阻止、删除或退出Cookie 的功能，则您可能会无法使用我们提供的一些网络提供服务或功能。
11. 保护未成年人的信息 Protection of Minors’ Personal data
We attach great importance to the protection of minors' personal data. If you are a minor under the age of 14, we will protect the confidentiality and security of your personal data in accordance with relevant laws and regulations.
If your guardian does not agree with you to use our services or provide us with information in accordance with this notice, please stop using our services immediately and notify us immediately. so that we can take corresponding measures.
12. 本通知的更新 Revision of the Notice
We may revise this notice from time to time. Please note that we will announce the latest revision on PH China Website【https://www.hartmann.info/zh-CN】