Directors and Executives' Privacy Notice

JSSR Logistics Company Limited (the “Company”) would like to assure the directors (the “Director”) and executives that the personal data of the Director and the Executive is important to the Company and the Company guarantee to protect and process those personal data under the best information security measures. The Company, therefore, intend to inform the Director and the Executive of this Director and Executive' Privacy Notice (the “Notice”) that defines the necessity that the Company may have in collecting, compiling, processing and/or disclosing the personal data of the Director and Executive for the performance of Company’s obligations as a company to You in accordance with the Civil and Commercial Code.

The Company may review and update this Notice from time to time to ensure that this Notice comply with the practice and relevant laws or regulations and the scope of delegation and authorization granted to the Director and/or the Executive; provided that the Company will notify the change of this Notice by announcing the updated Notice to the Director and the Executive via any communication channels of the Company.

Personal Data that the Company is processing

“Personal Data” includes information of Director and Executive that is personally identifiable. The Company may obtain or collect the Director and Executive’s Personal Data directly form the Director or Executive in the qualification examination form or registration of new Directors and Executives; or from the Company’s cross-examination of the Director and Executive Personal Data from the database of government authorities, or other reliable sources that relates directly to the verification of the Director and Executive qualifications under the relevant laws.

The Company need to collect and process the following Personal Data of the Director and/or Executive: 

1. Full name, date of birth, nationality, occupation, current address, bank account information, number of shares, Identification card number or passport, contact information (i.e., telephone number and/or email) of the Director or Executive;
2. Additional Personal Data of the Director or Executive that the Company may need to prepare in accordance with the form set by the regulatory authorities, including without limitation the Ministry of Commerce, or any other authorities, which include but not limited to resume of each Director or Executive, (i.e., educational record, work experience, directorship and a position in other company or business, training, marital status, spouse, minor children), photo as well as other qualification check of the Director and Executives in the form defined by any relevant government authorities;
3. Information of meeting attendance that such Director or Executive have attended which may include the meeting registration information and video and voice recorded during the meeting in both online and offline; and
4. Other Personal Data of Director or Executive that may be provided to the Company during the director or executive term and any other Personal Data that Director or Executive may submit to the Company to process for other particular purposes, including without limitation, the signature and copy of identification documents such as identification card or passport that the Company may need to attach and use in any transaction documents that such Director or Executive may undertake or transact in the name and on behalf of the Company, etc.

In addition to the direct Personal Data of the Director or Executive, in case that Director or Executive is a person who provide Personal Data of their related person such as spouse and minor children, upon the submission, the Company shall deem that the Director or Executive represent of their legitimate right to disclose such person’s Personal Data; have informed the related persons of the Company’s necessity to process such data; and have obtained the consent from such person, therefore, the Company shall have the right to fully process the Personal Data of such person.   

Objectives of the Personal Data processing

The Company would need to process the Personal Data of the Director or Executive for the following purposes:

1. To proceed with the selection process of Director or Executive, the Company may need to examine the qualification of the Director or Executive by checking and cross-examining with relevant government authorities;
2. To perform the Company’s legal obligations such as to manage the corporate matters (i.e. business restructuring or change of company registration); to deliver the meeting invitation and other notices to the Director as required under the relevant laws, for instance, the invitation to the board of directors meeting or the submission of the annual business report to the Director or the Executive in accordance with their statutory rights; to prepare the relevant accounting and tax report; and to perform any other legal obligations that the Company being limited company shall perform;
3. To perform the Company’s rights and obligations under the agreement between the Company’s and Director or Executive in controlling and managing the relationship between Director or Executive and the Company throughout the period of time such Director or Executive is in their office, including without limitation the process of Personal Data for communicating and coordinating between the Company and Director or Executive, the use of any Personal Data of Director or Executive for the operations that such Director or Executive may perform on behalf of the Company (including without limitation the use of their Personal Data on all of the communication and transaction that such Director or Executive transact on behalf of the Company with all vendors or relevant authorities), the use of any Personal Data to determine the consideration payment (such as the meeting allowances) as agreed under the relevant agreement and rules; and
4. To protect the legitimate interest of the Company or Director or Executive by ensuring the Company’s transparency and corporate governance. To comply with such instructions and guideline, the Company would need to process additional Personal Data of Director or Executive, in particular for the preparation of Company’s annual report or any publications through any Company’s channels particularly via Company’s publication and website. Also, for other legitimate interests, the Company may process the Personal Data of the Director and/or Executive for other purposes, such as for data analysis, for the purpose of data analysis, operating activities and facilitating the Director or Executive in any other special events that the Company may organize; for the risk management and internal control; for internal audit; and for the exercise of the Company’s right in the legal claims against the Director or Executive.

Retention Period of the Personal Data

The Company shall be required to process and store the Personal Data of the Director or Executive for all the purposes defined above as long as necessary (i) for all the period of time that the Director or Executive remain in the office and as long as the Company may have the obligations under relevant laws to perform to such Director or Executive; or (ii) as long as the Company may have the obligations under other relevant laws to retain the Personal Data of the relevant Director and Executive, for instance for the accounting period.

In addition, in order for the Company to protect their legitimate rights that the Company has with the Director or Executive, the Company reserve the right to retain the Personal Data for the period of time that is necessary to protect such rights, in particular, for the appropriate prescription period after the cessation of your shareholder status for the maximum of 10 years for general prescription period.

Disclosure of Personal Data

In general, the Personal Data shall not be disclosed to any person except in these necessary circumstances that the Company may need to disclose your Personal Data to the following person:

1. To third party service providers who provide support to the Company in the business operation and the performance of obligations that the Company may have with the Director or Executive or to protect the Company’s legitimate rights, including without limitation legal and accounting consultant, the service provider engaged to prepare the annual report and other counsels, as well as the internal and external audits; provided that the Company represent to only disclose your Personal Data under the defined purpose of data processing and on the necessary basis;
2. To the governmental authorities in case the Company shall be obliged under the applicable laws, court orders, or the instructions of such government authorities to disclose the Personal Data of the Director or Executive to, including the guidance of the Ministry of Commerce; and for the performance of this legal obligation, the Company may need to disclose the Personal Data on the public channel (i.e. website or other media) that any person can get access to;
3. To the counterparty where in some cases the Company may be required to disclose the Company’s annual report which may includes the Personal Data of the Director or Executive or the Company may need to attach the Director or Executive’s identity documentation to, for the purpose of executing contract or coordinating to them; provided that the Company shall only disclose the limited Personal Data without causing excessive impact on You as the data subject; and
4. To any other person that the Director or Executive have given explicit consent to the Company to disclose the Personal Data to.

Representation to implement appropriate information security measures

The Company undertake that the Company shall implement the appropriate security measures to prevent the unauthorized or unlawful access, amendment, change, or disclosure of your Personal Data. In addition, the Company shall establish internal policy to limit the access control or the use of your Personal Data in order to maintain data confidentiality and security and the Company commits to review those measures on the regular basis to comply with the industry standard and relevant laws.

Your Rights as the Data Subject

The Company acknowledge and respect your rights as the data subject in relation to your Personal Data that is in the Company's control. You can exercise your rights in accordance with the conditions under the applicable laws as follows:

1. Right to request for access and to obtain copy of the Personal Data including the right to request for the correction and update the Personal Data;
2. Right to request for data portability; 
3. Right to object to the process of Personal Data being undertaken by the Company;
4. Right to request for Personal Data erasure or de-identification when the Personal Data is no longer necessary to be processed or when the data subject has withdrawn the consent;
5. Right to request the Company to restrict the use of the Personal Data, in case the Personal Data shall be deleted or those Personal Data are not necessary to be processed; and
6. Right to withdraw consent that the You have given to the Company under the defined purposes.

The Director or Executive can contact the Company in order to make the request to exercise any defined rights through the defined communication channel. The Company will consider and notify the relevant Director or Executive of the Company’s determination within a reasonable period of time to the extent under the applicable laws. The Director or Executive can contact the Company at [email protected]