The protection of your personal data is a key matter of concern for the WTS China, an association (vereniging) established under the laws of China, Business certificate number 91310115342187047C (hereinafter “we”, “us” or “WTS China”). WTS China is part of the WTS Group, headquartered in Shanghai, China. A list of all WTS Group firms is available on www.wts.com.

In this Data Protection Statement, we would like to provide you with information on the handling of your data. The Statement concerns the collection, processing and use of personal data as part of the use of the WTS China website found at http://www.wts.cn (“Website”). We may amend this Data Protection Statement from time to time so it accurately reflects our processing activities.

1. Service provider and responsible organisation

The data controller for the personal data processed in the context of the Website is:

WTS China

Unit 06-07, 9th Floor, Tower A, Financial Street Hailun Center,

No.440 Hailun Road, Hongkou District,

Shanghai, China 200080
Tel. +86 (21) 5047 8665
Fax +86 (21) 3882 1211
E-mail: info@wts.cn

WTS China’s Business certificate number: 91310115342187047C

2. Subject of data protection
The subject of the data protection is personal data in accordance with EU General Data Protection Regulation 2016/679 (“GDPR”). Personal data includes details of personal or factual circumstances relating to an identified or identifiable natural person. This shall generally include all information that enables a natural person to be identified (at least indirectly), for example, by their name or contact details (e.g. telephone number, postal address and email address). IP addresses may also constitute personal data in this sense.

3. Collecting, processing and using personal data
As a rule, WTS China shall only collect, process and use personal data without your consent to the extent permitted or prescribed by the GDPR or other data protection laws and regulations, or with your consent, to the extent that you have consented to this as a user of our Website.

4. Automatic collection, processing and use of data during your visit to our website
When you visit our Website, it is not necessary for you to actively enter information about yourself. However, we collect specific data, either anonymously or by using a pseudonym, in order to evaluate your usage behaviour for our legitimate business interests, which may include marketing, research and analysing the use of our Website the effectiveness of our services. In addition, cookies are used on our Website. Cookies are small data packets created by our web server and filed on the hard drive of your computer or other device to enable your computer or device to communicate with the server.

4.1 General right of objection
You may exercise your right to reject or delete cookies at any time. Should you wish to do this, you can adjust your browser accordingly without prejudice to the other opt-out opportunity set out below. Please refer to the Help function on your browser for details on how to do this.

If you do not accept cookies, you may be unable to use the full range of functions on our Website.

4.2 Types of cookies
The following types of cookies are used on our Website:

Session cookies

To improve presentation and navigation; these become invalid after you leave the Website.

4.3 Utilization of social media plug-ins

Our Website makes use of various social media plug-ins to promote our media channels and to make it easy to share content you find on our Website via LinkedIn. As a result, cookies may be set by these third parties and used by them to track your online activity, which may entail the processing of personal data. The media plugins on the Website are subject to the privacy policy or privacy terms of the relevant social media network.

5. Collection, processing and use of data manually entered by you on the website
If you request publications (such as the WTS China Info Letter, International WTS China Journal, WTS China Journal, WTS China Tax Weekly) or press releases from us via the Website, register for seminars, subscribe to newsletters or (other) periodic updates (howsoever issued) or otherwise wish to contact WTS China, we require you to enter specific information about yourself. You can provide this information manually at the appropriate place on our Website. In principle, we shall collect, process and use this data only for the required purpose, for example for processing your requests and/or for sending the respective publication. If, in exceptional circumstances, data is collected, processed and used for other purposes (Point 3.2, Point 5.5), this will only be carried out based on declarations of consent or if this is in our, or a third party’s, legitimate business interests, or if we are required to process personal data by law.

5.1 Sending publications for which consent is required
5.1.1 Details to be entered
If you request publications (such as the WTS China Info Letter, International WTS China Journal, WTS China Journal, WTS China Tax Weekly) from us by email, or subscribe to newsletters or (other) periodic updates (howsoever issued) you simply need to enter your email address. In contrast, when requesting publications by post (WTS China Journal only), it is mandatory to specify your first name, surname and address details.

In both cases (post and email distribution), we shall only collect and process further details from you to the extent that you voluntarily disclose such information.

Overall, you can always enter the following information (“Aggregate Data”) when requesting publications:

• Salutation
• Title
• First name
• Last name
• Company
• Department
• Telephone
• Fax
• Street address
• Postcode
• City
• Country
• Email address

5.1.2 Declaration of consent

We only send publications (such as the WTS China Info Letter, International WTS China Journal, WTS China Journal, WTS China Tax Weekly), newsletters and period updates based on previously granted consent, unless otherwise permitted under applicable law. If you have granted us your consent to use your data to send publications (electronically and/or by post), the consent is worded along these lines:

I hereby declare that I give my consent for the personal data provided by me to be collected, processed and used for sending the publications, newsletters or other types of information requested by me. I may revoke my agreement to this at any time in the future and, in so doing, unsubscribe from the respective publication. I can find detailed information on this in the Data Protection Statement and in publications received by email at the end of the respective email in which they were sent.

5.2 Sending electronic press releases for which consent is required
5.2.1 Details to be entered
When ordering electronic press releases, all you need to do is enter your email address. Optionally, in addition to the Aggregate Data listed under Point 5.1.1, with the exception of Company/Department and Country, you can provide information on the press medium in which you work, whether you work as an editor or freelance journalist and the area of the press in which you work.

5.2.2 Declaration of consent
We also only send press releases based on previously granted consent. If you have granted us your consent to use your data for the purpose of sending press releases electronically, the consent is worded along these lines:

I hereby declare that I give my consent for the personal data provided by me to be collected, processed and used for sending electronic press releases. I may revoke my agreement at any time in the future and, in so doing, unsubscribe from the respective press release. I can find detailed information on this in the Data Protection Statement and at the end of each press release.

5.3 Seminar registrations
If you have registered for a seminar, we will only use your data for conducting the seminar. If you have granted us your consent for this, we will also use your data to send you by email, in connection with your participation in the seminar, a link to an electronic evaluation questionnaire and an electronic form, giving you the opportunity to create your interest profile.

5.3.1 Details to be entered
If you are registering on our website to attend a seminar, all Aggregate Data listed under Point 5.1.1 shall be required with the exception of Title and in addition to entering your role within your company. If necessary, there may be an option to enter additional data depending on how the seminar is arranged. For more information, please see the appropriate registration form on our website.

5.3.2 Optional declaration of consent
If you have granted us your consent to send you an electronic evaluation questionnaire and an electronic form by email to create your interest profile following the seminar, the consent is worded along these lines:

I hereby declare that I give my consent for my personal data to also be collected, processed and used to send me by email, after my taking part in the above-named seminar, a link to an electronic questionnaire relating to the respective seminar and an electronic form, which I can use to produce an interest profile relating to future events and purchasing WTS China publications. As explained in detail in the Data Protection Statement, I may revoke this consent at any time in the future.

5.4 Other methods of contact
You can also send us a message using the general contact form on our websites. To do this, you are required to enter your full name and either your email address or telephone number to enable us to contact you. There may also be the option of providing the Aggregate Data listed under Point 5.1.1.

5.5 Processing and use of your data based on consent for customer service
If you have granted us your consent for this, exceptionally we will also use the data collected for the purposes stated under Points 5.1 to 5.4 for customer services. This means that we will save your data for information purposes and, in cases of repeated contact or a prospective business relationship, for example, use it to enable us to respond to your requests in the best possible way.

If you have granted us your consent to use your data for the purpose of customer service (to the extent required under applicable law), the consent is worded along these lines:

I hereby declare that I give my consent for the personal data provided by me to be processed and used by WTS China and other entities of the WTS Group (as indicated on the website of WTS Global) for customer service. As explained in detail in the Data Protection Statement, I may revoke this consent at any time in the future.

5.6 Revocation of declarations of consent
Any consent given via the Website can be withdrawn in any form at any point in the future here or by writing to:

WTS China

Unit 06-07, 9th Floor, Tower A, Financial Street Hailun Center,

No.440 Hailun Road, Hongkou District,

Shanghai, China 200080
Tel. +86 (21) 5047 8665
Fax +86 (21) 3882 1211
E-mail: info@wts.cn

You shall not incur any costs for this withdrawal, with the exception of any potential transmission or connection charges.

We shall not use your personal data without your consent for the purposes for which the consent is required, unless permitted by law. This shall also apply if you withdraw the consent originally granted at a later date. We do not store your personal data for longer than is necessary for the purposes for which the personal data are processed.

6. Transmitting your data to third parties
Where necessary in the context of performing our services or operating our business, or to meet your request or query, we shall pass on personal data to companies within the WTS Group. We may also pass on personal data to third parties employed by WTS China with regard to data processing (‘data processors’), taking into consideration data protection requirements. In principle, we do not actively transmit personal data collected via our Website to countries outside the European Union or European Economic Area. In the event that personal data are transferred outside the European Union or European Economic Area, we will ensure that additional safeguards are in place. Please contact us for more information in this regard. Anything else shall only come into question in the instance explained in Point 4.2.

7. Your rights to information, correction, blockage and deletion
You have the legal right to know which personal data WTS China has collected from and about you and to whom we have provided these data.

You have the right to: lodge a complaint with the Dutch Data Protection Authority (Autoriteit Persoonsgegevens), correct, block, limit, and delete your personal data, and to object to the processing of your personal data when processed for direct marketing purposes or our, or a third party’s, legitimate business interests, in accordance with the statutory provisions of the GDPR, to the extent that it applies.
Please direct any requests in this regard to our managing partner Martin Ng at martin.ng@wts.cn. We will use reasonable efforts to respond within the timeframes provided for by law. We may disregard excessive requests.