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    Privacy Notice for China Residents

    This Privacy Notice (Privacy Notice) describes how your personal information may be collected, used, disclosed, or otherwise processed in accordance with the Personal Information Protection Law of the People’s Republic of China (PIPL), as may be amended from time to time, by IMD SE Asia Pte. Ltd. (hereafter referred to as “IMD SEA” or “we” or “us”). Personal data refers to any data, whether true or not, about an individual who can be identified (a) from that data or (b) from that data and other information to which we have or are likely to have access (Personal Data).

    IMD SEA is an affiliate of the International Institute for Management Development, a Swiss-based foundation established in Lausanne, Vaud (IMD). Apart from IMD SEA, IMD has other affiliates (collectively referred to as the “Affiliates” of IMD SEA).

    This Privacy Notice applies to any processing of Personal Data of individuals carried out by IMD SEA and/or by any third-party person or entity on behalf of IMD SEA (Processors), including collection, storage, sharing, using, and analyzing (Processing Activities).

    1. Scope of Privacy Notice

     This Privacy Notice applies to all Processing Activities that are carried out by IMD SEA in relation to its:

    (a) website (IMD.org/asia/imd-china/), social media pages, and other of its online platforms as well as mobile applications (collectively, our “Online Platforms”);
    (b) programs and courses, in person and/or online (including any assessments, reports, or other pedagogical tools);
    (c) conferences, events;
    (d) fundraising and networking activities;
    (e) marketing and communication activities, including newsletters, banners, advertisements;
    (f) management of the IMD alumni community;
    (g) research and other scientific activities (including statistics); and
    (h) management, processing, and monitoring of applications and pre-recruitment procedures for prospective students and employees.

    1.2 Please note that this Privacy Notice does not apply to the Processing of Personal Data for employees and Board members of IMD SEA, who are subject to a separate privacy notice. For more information, please contact the Data Protection Officer below.

    2. Collection, use, and disclosure of Personal Data

    2.1 In compliance with the PIPL, IMD SEA collects, uses, and discloses to third parties specified categories of Personal Data to fulfill certain purposes (Purposes). Information on the Purposes and how IMD SEA collects, uses, and discloses Personal Data is set out below.

    2.2 Types of Personal Data IMD SEA may collect about you:

    (a) browsing-related data (including pages visited, path on a webpage);
    (b) device-related data (including hardware model, operating system version, or unique device identifier);
    (c) log information (including your internet protocol address and device and event information, which can include crashes as well as system activity);
    (d) geographical location;
    (e) personal data as communicated by you;
    (f) identification data (name, surname, date of birth, etc.);
    (g) contact details (email address, postal address, emergency contact person and details, etc.);
    (h) financial data (payment details, payment means, etc.)
    (i) professional data (position, company, professional biography, financial information when available, etc.);
    (j) program and/or course-related data (subscription data, attendance data, grades and exams, etc.);
    (k) attendance data;
    (l) history within IMD (programs and courses, grades, conferences, etc.);
    (m) data on participation in events (attendance, payment details, etc.);
    (n) behavioral and personality data derived from surveys, IT programs, or other educational contexts;
    (o) any personal data contained in filmed interviews;
    (p) individual photos and filmed interviews,
    (q) general photos and videos (without an individual scope)
    (r) available personal data on social networks;
    (s) publicly available data; and
    (t) any other information you provide us with.

    2.3 Purposes for which IMD SEA may use your Personal Data:

    (a) analytical purposes;
    (b) enhancing our services, web and social media sites and presence, and your experience;
    (c) security purposes;
    (d) functioning of certain IMD SEA mobile applications and online platforms;
    (e) services provided through the IMD SEA mobile applications and online platforms;
    (f) creation and management of your personal account (MyIMD);
    (g) general management of programs, conferences, events, and/or courses;
    (h) tailoring our programs and/or courses;
    (i) enabling networking among students, alumni, and participants;
    (j) enabling you to take part in events and conferences organized by or in relation to IMD SEA;
    (k) communication on future events and conferences;
    (l) enhancing your profile within IMD SEA;
    (m) providing you with scholarships;
    (n) performing surveys and assessments in relation to IMD SEA’s programs and courses, as well as development of pedagogical tools;
    (o) fundraising activities;
    (p) following up on payments and donations;
    (q) sending newsletters and general communication on IMD SEA’s activities;
    (r) communicating with you;
    (s) management of our relationship;
    (t) managing IMD’s business development activities, as well as prospecting business development activities;
    (u) management of the alumni community;
    (v) pursuing research and scientific activities;
    (w) providing you with an analysis of aspects of your personality, including professional activity; and
    (x) teaching and research.

    2.4 IMD SEA may disclose your Personal to the following third parties to fulfill the Purposes:

    (a) other participants
    a. in the same program cohort for limited identification and contact details;
    b. of the same conference and/or event;
    (b) your employer and/or company sponsoring your participation in our programs, conferences, events and/or courses;
    (c) catering and/or hosting partners; sub
    (d) speakers;
    (e) third-party fundraising entities (in certain limited situations);
    (f) alumni clubs and/or the IMD International Alumni Association;
    (g) partner universities and research institutions; and
    (h) other participants and the general public through IMD SEA’s teaching material and communication activities.

    3. Disclosure of Personal Data to third parties

    3.1 IMD SEA may also disclose your Personal Data to the following categories of recipients:

    (a) Processors and subcontractors who support IMD SEA in performing its services, through various software used in IMD SEA’s courses and programs to continually improve our online services and learning experiences. A list of such Processors and subcontractors may be made available on request to the Data Protection Officer (“DPO”).
    (b) IMD SEA Affiliates, when organizing courses, programs, and events.

    3.2 We do not disclose your Personal Data to third parties for their independent use without your consent unless such disclosure is permitted under the PIPL or any other applicable laws. Third-party recipients of your Personal Data are also contractually bound to respect the security and confidentiality of your Personal Data pursuant to agreements and to treat your Personal Data in accordance with applicable data protection laws.

    3.3 IMD SEA may also communicate your Personal Data to third parties when we are ordered or obliged to do so because of a court order, governmental authority, and/or by law.

    3.4 Should you have any questions on the above or require any further information, please contact the DPO.

    4. International transfers of Personal Data

    IMD SEA may transfer your Personal Data to countries outside of China, including to IMD SEA Affiliates. If we do, we will take necessary steps to ensure that the overseas recipient provides a standard of protection for your Personal Data that is at least comparable to that provided under the PIPL.

    5. Cookies

    For information relating to our use of cookies, trackers, and/or online pixels, as well as to know how to communicate to us your choice regarding the Personal Data collected through them, please refer to our Cookie Policy. Please note that when allowing third-party cookies on your browser, such third parties may themselves collect Personal Data for their own purposes.

    6. Retention of Personal Data

    IMD SEA will only retain your Personal Data for as long as is necessary for us to process your Personal Data and to fulfil the Purposes or where we may have legal or business reasons for doing so. Please be advised we may continue to retain your Personal Data after you cease to use our services, for instance if the Personal Data is necessary to meet our legal obligations, such as retaining the Personal Data for tax, legal, and accounting purposes.

    7. Security of Personal Data

    7.1 IMD SEA takes reasonable precautions to protect your Personal Data from unauthorized access, use, disclosure, copying, modification, or similar risks.

    7.2 IMD SEA takes precautions to protect Personal Data in our possession from loss and misuse as well as unauthorized access, disclosure, alteration, and destruction. We also maintain physical, electronic, and procedural safeguards that comply with applicable laws to safeguard Personal Data.

    7.3 At IMD SEA, we make every effort to follow industry-standard security. However, no data transmitted through the Internet and/or stored on servers is 100% secure. As a result, we are unable to guarantee that any Personal Data covered by this Privacy Notice will be entirely secure. That being said, we do work to limit these risks. You are solely responsible for keeping your login information and passwords confidential.

    8. Your rights

    8.1 In accordance with the PIPL, you may be entitled to:

    (a) request access to your Personal Data which is being processed and receive a copy of it;
    (b) request that we correct your Personal Data in our possession; and
    (c) withdraw consent for the collection, use, or disclosure of your Personal Data.

    8.2 You may access and/or correct any of the Personal Data you have provided us by logging into your MyIMD account and updating your personal particulars if you wish. It is your responsibility to ensure that the Personal Data used in the context of your profile and activities with IMD SEA is up-to-date and correct.

    9. Updates to the Privacy Notice

    IMD SEA reserves the right to update or modify this Privacy Notice. The changed text will be posted on this page. We recommend that you check this page periodically for updates. Your continued use of our Online Platforms and services constitutes your acknowledgement and acceptance to be bound by such changes.

    10. Contact Us

    If you have any comments, questions, or complaints, please contact our Data Protection Officer at [email protected].