Ping An (“we” or “us”) values your privacy and the security of your personal information is important to us. This Privacy Policy (hereafter referred to as "this Policy") informs you about how and why we collect, use, and disclose your personal information through the following Ping An website: group.pingan.com (the “Site”). As Ping An provides a variety of websites, products and services, some of them have independent and specific privacy policies, please note that this Privacy Policy does not apply to other Ping An websites, products and services with their own applicable privacy policies.

We remind you: please be sure to carefully read and thoroughly understand this Policy before submitting your information to Ping An; By visiting the Site, you agree that your information will be handled as described in this Policy. Your use of our Site, and any dispute over privacy, is subject to this Policy and our Terms of Use, including its applicable limitations on damages and the resolution of disputes. Our Terms of Use are incorporated by reference into this Policy. You should not use the Ping An Site if you object to the practices described under this Policy.

If you have any queries or comments, please contact us using the information set out in section XI.

Definitions

1. Ping An Insurance (Group) Company of China, Ltd / We: the operator and provider of this Site.

2. Personal information: a variety of information you provide in order to use this Site, including but not limited to account registration information, names, contact information, platform registration information and email addresses.

This Policy includes the following

I. How We Collect Personal Information

II. How We Use Personal Information

III. How We Store Personal Information

IV. How We Share Personal Information

V. How We Protect Personal Information

VI. Cookies and Other Automatic Collection Tools

VII. Your Control over Personal Information

VIII. Third-Party Sites and Services

IX. Notification of Amendment

X. Children and Privacy

XI. Our Contact Information

I. How We Collect Personal information

We collect information directly from you, from third parties and other sources, and by automated means as set out below. The type of information that we collect from you depends on your particular interaction with our Site, but generally includes the below information.

       1. Information you provide directly

The Site may ask you to submit your personal information directly, for example by subscribing to receive information from us or by using completing contact forms. The information we collect may include name and email address.

        2. Automatic collection                                                                          

When you are using our Site, we may collect your information through automatic collection tools such as cookies, local storage, analytic tools and other technologies, such as your log files, IP address, device identifier, hardware model, operating system version, location information, browser type, device type, domain name, the website that led you to our Site, the website to which you go after leaving our Site, the dates and times you access our Site and perform certain activities; device name and model; the length of time that you are using our Site, and the links you click and your other activities within the Site (“Usage Data”). We may combine Usage Data with other information that we have collected about you. Please see the section “Cookies and Other Automatic Collection Tools” below for more information.

       3. Information from affiliates

We may obtain your information from our affiliates within the same company group and joint venture partners.

       4.Information from third parties

We might collect and validate your information through third parties, including but not limited to your platform registration information and email address.

       5. Information obtained from public sources

II. How we use personal information

The purposes, means and scope of our use of your personal information are slightly different in different scenarios. Below please find the details:

1. Providing our Site to you
2. Working together with third parties to validate and match your identity information so as to confirm it is your operation
3. Communicating with you or responding to your queries and requests, or providing updated information to you, including but not limited to changes of which we think it necessary for us to notify you
4. Using the information for monitoring the performance and stability of our Site, optimizing its performance, and supporting us in improving its quality
5. We may collect and use your personal information where required or otherwise permitted to do so by applicable laws, including where we reasonably determine that collection, use or disclosure of your information is required in the following situations:

• For national security, and national defense security purposes;
• For public security or public health purposes, and to protect major public interests;
• For the purposes of exercising, establishing or defending our legal rights, or to support a criminal investigation, lawsuit, trial or enforcement of judgment;
• For the sake of safeguarding your or a third party’s vital interests, and where it is not reasonably possible to gain your consent;
• For the purposes of scientific research or statistical analysis based on public interests; and when results are provided externally, personal information contained in the results is de-identified

      6. Where necessary for the administration of our general business, accounting, recordkeeping and legal functions.  As part of our routine business administration, such as employee training, compliance auditing and similar internal activities

It is possible to use the Site without providing any personal information (except for any personal information which is collected by cookies and similar technologies, and which is strictly necessary for the Site to function).  If you want to get in contact with us, or you want to subscribe to receive information from us, you will need to provide us with contact information.  Otherwise, where personal information is required for specific products or services available on the Site, we will make this clear.

Legal Bases for Processing Personal Information

Certain laws, including the General Data Protection Regulation (“GDPR”), require us to have a “legal basis” that justifies each use of your personal information.  To the extent that our use of your personal information is caught by the GDPR (or equivalent laws), we rely on the following legal bases:

• Performance of contract: processing of your personal information which is required for us to perform obligations or exercise rights under any terms of service or terms of use that we enter into in relation to the use of this Site.
• Compliance with laws: to comply with our legal obligations (for example, maintaining information in accordance with tax, audit or company law requirements, or to make disclosures of your personal information that are required by law (see item 5 in the list of purposes for which we use your personal information, above)
• Our legitimate business interests: in furtherance of our legitimate business interests including:
• to facilitate your participation in interactive features you may choose to use on our Site and personalize your experience by presenting content tailored to you
• to correspond with you or respond to your queries and requests for information
• to send you advertising material via email, such as surveys and promotions (except where consent is required under applicable laws)
• for data analysis, audits, fraud monitoring and prevention, and developing new products, enhancing, improving or modifying our Site, identifying usage trends, determining the effectiveness of our promotional campaigns and operating and expanding our business activities
• to protect and defend our legal rights and interests and those of third parties
• With your consent: where applicable laws require that we obtain your consent to collect and process your personal information, we will obtain your consent accordingly.  We may collect consent to send you direct marketing, to the extent that we cannot rely on our legitimate business interests to do so.

When we obtain your consent, the GDPR (where it applies) and other applicable laws give you the right to withdraw your consent. You can do this at any time by contacting us using the details at the end of this privacy notice. In some jurisdictions (not including where the GDPR applies), your use of the Site may be taken as implied consent to the collection and processing of personal information as outlined in this privacy notice.

III. How We Store Personal Information

1. Region

We are established in China, and we operate and may continue to operate servers there and in a number of other jurisdictions around the world.  Therefore the server on which your personal information is stored may not be in your jurisdiction.  You should be aware that the counties in which your data is stored may not have data protection laws equivalent to those in your country of residence.

Where required to do so by applicable laws, we enter into transfer mechanisms with third parties (including service providers) to whom we transfer your personal information, in order to safeguard an appropriate level of protection for your information.  Where certain data protection laws, including the GDPR, apply, you have a right to find out more about the transfer mechanisms we use.

Where such consent is required under applicable laws, you consent to the transfer of your personal information (both inside and outside of your jurisdiction) for the purposes described in this Privacy Policy.

         2. Period

Unless otherwise stipulated by laws and regulations, we shall store your personal information:

1) During the period when you are using our Site, we will we retain your personal information for so long as is necessary to fulfill the purposes set out under this Privacy Policy.

2) Notwithstanding the foregoing Clause 1, you still have the right to delete such information at your own discretion or close your account (if any) or update your marketing preferences as permitted by relevant technical settings.

3) Notwithstanding the foregoing Clause 2, we shall continue to store your personal information as required by applicable laws and regulations until such legal obligations are exempted, or where we believe it is necessary to establish, defend or protect our legal rights and interests or those of others.

We may also retain aggregated or otherwise anonymized information (which does not constitute your personal information) indefinitely, for our own business purposes.

IV. How We Share Personal Information

We may share your personal information as follows:

      1. Affiliates, partners and service providers sharing the information

We may share personal information with affiliates, partners and service providers, in order to operate the Site, and to communicate with you. These third parties provide us with a range of assistance, including technical support, information analysis, technical infrastructure, analysis of usage of online services, measurement of efficiency of ads and services, provision of customer services, surveys and analysis.

       2. Sharing requirements

We will use reasonable efforts to ensure that such third parties (i) only use your personal information for specified purposes that are consistent with this Privacy Policy; and (ii) take reasonable confidentiality and safety measures to protect your personal information.

       3. Other sharing of your personal information

We may also share your personal information where:

1) we have obtained your prior authorization or approval;

2) disclosures are required by applicable laws, regulations, legal procedures, or in response to a government order, a judicial proceeding, court order, or other legal process, such as in response to a court order or a subpoena;

3) we believe it is appropriate to do so in order to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety of any person, violations of any contract you have entered into with us, or as evidence in litigation in which we are involved;

4) we or our affiliates are or may be acquired by, merged with, or invested in by another company, or (ii) if any of our assets are or may be transferred to another company, whether as part of a bankruptcy or insolvency proceeding or otherwise, we may transfer the information we have collected from you to the other company.  As part of the business transfer process, we may share certain of your personal information with lenders, auditors, and third party advisors, including attorneys and consultants.  In such cases, we will use reasonable efforts to ensure that the acquirer of your personal information continues to abide by this Privacy Policy, or otherwise obtains your authorization to use your personal information for different purposes; and

5) we may disclose aggregate, anonymous, or de-identified information for marketing, advertising, research, compliance, or other purposes.

Where such consent is required under applicable laws, you consent to the sharing and transfer of your personal information (both inside and outside of your jurisdiction) as described in this “How We Share Personal Information " section.

V. How We Protect Personal Information

We take appropriate safety and technical measures in accordance with industry standards to protect your personal information. These measures include internal information management procedures, data encryption, accountability mechanism, and access and control permission.

Our employees are only permitted to access or use such information on a need-to-know basis. Meanwhile, we also require them to comply with obligations of confidentiality.

If your personal information security is affected by a security event, we may need to notify you about it via email, SMS, telephone and/or push notifications according to the contact information you provided, and we may also provide suggestions on reduction or prevention of relevant risks.

If necessary, we will report this to relevant authorities according to applicable laws and regulations. We endeavor to respond in a timely manner to security risks such as system vulnerabilities, cyberattacks, viruses, and cyber intrusions.

VI. Cookies and Other Automatic Collection Tools

We will use cookies and other technologies to record information about your use of our Site, including but not limited to your IP address, device identifier, hardware model, OS version, location and service logs. Such technologies improve the functionality of our Site and your user experience, and also help us better understand user's behaviors and your browsing history, facilitating understanding and improvement of products, services, and online searches.

Cookies are alphanumeric identifiers that we transfer to your device’s hard drive through your web browser for record-keeping purposes. There are two types of cookies: session and persistent cookies.

• Session Cookies. Session cookies exist only during an online session. They disappear from your device when you close your browser or turn off your device. We may use session cookies to allow our systems to uniquely identify you during a session or while you are logged into the Site.
• Persistent Cookies. Persistent cookies remain on your device after you have closed your browser or turned off your device. We may use persistent cookies to track aggregate and statistical information about user activity.

Many cookies are important. For example, cookies record your account information to avoid re-inputting registration information, or help you judge account security. Other cookies help us understand your way of browsing our Site for the improvement purpose. By using relevant analysis tools, we can analyze the load time, users' visits as well as information most frequently viewed by visitors. Cookies help us find out something that is below our expectation, urging us to make corrections and provide better content for you.

All the most popular browsers allow you to manage your cookies. You can accept or refuse all cookies, or refuse specific cookies. You will only have access to part of our Site after turning off cookies.

Currently, our systems do not recognize browser “do-not-track” requests. You may, however, disable certain tracking as discussed in this section (e.g., by disabling cookies).

VII. Your Control over Personal Information

We respect your control and authority over your personal information, and provide you with measures to help you control your personal information. You have the right to enquire about, correct, manage and delete your own personal information and protect your privacy.

For your updating, management and deletion of your personal information, we do not charge you any fees in principle. However, for multiple repeated requests, and excessive and unreasonable requests, we will charge you a certain cost as appropriate, or postpone or reject your requests.

In addition to the rights referred to above, depending on applicable laws you may have additional rights in respect of your personal information, including:

1. to obtain from us confirmation as to whether or not personal information concerning you is being processed, and where that is the case, to request access to the personal information, together with certain information about how or why it is being processed; 
2. to have the processing of your personal information restricted where you dispute its accuracy, if you think its processing is unlawful, or if you otherwise object to its processing, or when we no longer need your personal information but you need it in relation to a legal claim;
3. to have your personal information provided to you in a portable copy, or ported to a third party;
4. to object at any time to any processing of your personal information which has our legitimate interests as its legal basis. If you raise an objection, we have an opportunity to demonstrate that we have compelling legitimate interests which override your rights and freedoms. The right to object does not exist, in particular, if the processing of your personal information is necessary to take steps prior to entering into a contract or to perform a contract already concluded;
5. to prevent us from contacting you for direct marketing purposes;
6. to obtain a copy of, or reference to, the safeguards under which your personal information is transferred outside the EEA/United Kingdom. We may redact data transfer agreements to protect commercial terms; and
7. to complain to your local supervisory authority if you have concerns about our processing of your personal information.

If you need to exercise any rights in respect of your personal information, you may contact us through our contact information in Section XI.

VIII. Third-Party Sites and Services

Our Site may contain links to third-party websites. Any access to and use of such linked websites is not governed by this Policy, but instead is governed by the privacy policies of those third-party websites. We are not responsible for the information practices of such third-party websites.

IX. Notification of Amendment

We may change this Privacy Policy from time to time, so please be sure to check back periodically. We will post any changes to this Privacy Policy on our Site. If we make any changes to this Privacy Policy that materially affect our practices with regard to the personal information we have previously collected from you, we will endeavor to provide you with notice in advance of such change by highlighting the change on our Site.

X. Children and Privacy

Our Site does not target and is not intended for children under 18 and we do not intentionally collect personal information on our Site from those we actually know are under 3. If we discover that a child under 13 has provided us with personal information, we will delete such information from our systems.

XI. Our Contact Information

We are delighted to provide all necessary assistance to you.

Please note that, dependent on applicable law, various exemptions may apply that mean we cannot, or are not required to, comply with a request in respect of your personal information.  These exemptions include but are not limited to:

1) national security and national defense concerns;

2) public security, public health, and significant public interest concerns;

3) tour need to establish, exercise or defend legal claims, or to assist with a criminal investigation, lawsuit and trial;

4) the protection of the privacy or rights of a third party; and

5) preservation of legal privilege.

If you have any query or comment about this Privacy Policy, or you wish to exercise any rights in respect of your personal information, please contact us via the following means. We will endeavor to reply to you in a timely manner, and within all relevant statutory periods. Please contact us at pr@pingan.com.cn