我们致力保障所有访问www.abrdn.com 网站(“网站”)的人士的隐私。接收我们网站上的信息或使用服务不会要求您提交您的个人信息。我们使用cookies（详情请浏览第9段），当您浏览本网站时，我们将会存储关于您如何使用网站的信息，以改善为您提供的服务质量。例如，这让我们能够确定最适合的网站版面和导航。我们提供与外部第三方网站和标准人寿安本集团其他网站的链接。我们提醒您注意，这些网站可能会向用户发送自己的cookies，或以其他方式收集或索取个人资料。我们不就您访问我们网站时的信息收集行为承担责任，并且鼓励您在披露任何个人可识别资料之前，查看每个网站的隐私政策。

Introduction

Definitions

General

abrdn Private Fund Management (Shanghai) Company Limited is committed to protecting any personal information shared with us. We take privacy seriously and we will only ever collect and use personal information where it is necessary and lawful to do so.

This Privacy Notice applies to abrdn Private Fund Management (Shanghai) Company Limited and contains important information about what personal information we collect; what we do with that information; who we may share it with and why; and your choices and rights when it comes to the personal information you have given us.

We may need to make changes to our Privacy Notice; so please check our website for updates from time to time. If there are important changes to how we handle your personal information; we may contact you to let you know.

If there is any inconsistency between the English version of our Privacy Policy and the Chinese translation, the English version will take precedence.

abrdn Private Fund Management (Shanghai) Company Limited is a subsidiary of abrdn plc; a global business providing a range of savings and investments products and solutions to meet customer and client needs.

Personal information we collect and use

We may collect and use personal information including:

• Information about who you are for identification and security purposes e.g. your Full Name, Date of Birth, Gender, Marital Status, Country of birth, National Identification Card Number, Nationality, Passport Number, Expiry Date and Place of Issuance, Occupation and employment details including job title, salary and employer’s address;
• Information to allow us to contact you e.g. Address (current address in Shanghai and Registered home address if different), Telephone (mobile) number, Email address;
• Information connected with your product or service with us e.g. bank account and sort code
• Information about your contact with us e.g. phone calls, emails / letters;
• Information that is automatically connected e.g. via cookies when you visit one of our websites; and
• Information described as ‘sensitive personal information i.e. personal information that, if leaked or used illegally, may easily cause harm to the dignity of natural persons, or serious damage to the safety of individuals and properties, including information relating to biometric identification, religious beliefs, specific identities, healthcare, financial account, individual location tracking, etc., as well as personal information of minors under the age of 14., as prescribed by the Personal Information Protection Law (PIPL). Such sensitive personal information will only be collected and used where it’s needed to provide the product or service you have requested or to comply with our legal obligations, and where we have also obtained your explicit consent to process such information.

Information on persons connected to you, where required to provide the agreed product or service e.g. name, date of birth, nationality, National ID number or Passport Number of your spouse or beneficial owner .If you have a distributor / broker / agent, the information we collect and use will most likely have been provided by them on your behalf.

Why we collect and use your personal information

We take your privacy seriously and we will only ever collect and use your information where it is necessary and lawful to do so. We will collect and use your information only where we can satisfy one of the lawful processing conditions set out in the data protection laws. These include:

• Where it’s necessary to provide the product or service you have requested e.g. if you wish to invest in one of our funds or products we will require some personal information which may include your name, address, date of birth, and bank account details;
• Where it’s necessary for us to meet our legal or regulatory obligations e.g. to send you Annual Statements, tell you about changes to Terms and Conditions or for the detection and prevention of fraud;
• For our legitimate interests where such interest does not override yours as the data subject e.g. to develop new products and services for our customers; and
• For the performance of a task we require to carry out in the public interest You have given us your explicit consent to use your information for an agreed purpose. For example, if we are transferring your personal information out of the People’s Republic of China for processing activities provided prior approval is obtained from the relevant local authorities. 

Subject to the above, we may use your personal information for the following purposes:

• Account opening including information verification and credit checks
• Order Handling
• Unit Allocation
• Regulatory and Compliance Reporting
• Marketing and Research including analysis and promotion
• Call Handling (Incoming and outgoing)

You will be required to provide the personal information as required to be processed by or on behalf of us, as described above. If you do not agree to provide such personal information to us in accordance with this Notice, we may not be able to provide you with the product(s) or service(s) requested or comply with any of our contractual obligations owing to customers.

Proper Management and Protection of Personal Information

We take personal information and security very seriously and we strive to comply with our obligations at all times. Any personal information which is collected and used by us in any way will have appropriate measures in place to properly manage and protect your personal information. We have implemented the following measures:

• Established an organizational culture to promote and ensure protection of all personal information held by us;
• appointed personal information controllers to oversee the proper handling of your personal information;
• established internal company rules based on Personal Information Protection Laws and guidelines issued by the relevant authority to ensure proper handling of personal information;
• educated our employees to ensure that they understand the importance of personal information protection and are thoroughly familiar with all relevant rules and guidelines;
• established a personal information management register and enforcement of appropriate restrictions on access to personal information; and
• implemented appropriate and reasonable security measures [including a secure storage method with restricted access controls] to prevent unauthorized access to, or leakage, destruction or alteration of, personal information. Our security controls are aligned to the local legal and regulatory requirements; providing an appropriate control environment that manages risks and compliance to the confidentiality, integrity and availability of your personal information.

Disclosure of Personal Information to Third Parties

We may share your personal information with third parties we work with for the purposes outlined in ‘Why we collect and use your information’.

We will only disclose your Personal Information to such third parties where it is lawful to do so and in line with our obligations under data protection laws.

We will share your information with the following parties within Mainland China unless specified:

• Other parts [subsidiaries, holding companies, related corporations or associates of ours whether present or future] of Standard Life Aberdeen plc who support us in the provision of the product or service you have;
• Companies and partners we have carefully chosen to support us, both inside and outside of Shanghai;
• Credit reference agencies for the purposes of conducting a credit check and ID verification
• Your distributor / broker / agent where this is required as part of the product or service you have agreed with us;
• Our regulators in and outside of Shanghai including the China Securities Regulatory Commission (CSRC), the Office of the Cyberspace Administration of China (CAC), the Financial Conduct Authority;
• Appointed agencies [government agencies, public agencies, agencies ]responsible for supervising the provision of services;
• Law enforcement agencies e.g. for the prevention and detection of crime, pursuit of legal proceedings;
• Other third parties where required to support an organization restructure, amalgamation, merger or sale; and
• Our regulators outside of Mainland China including the Information Commissioner's Office (the ICO) in the UK and Monetary Authority of Singapore (MAS) and any other third parties where required to support our services providing prior approval of such information sharing is obtained from the relevant local authorities.

By disclosing your personal information to such third parties we shall ensure that those persons shall treat your Personal Information confidential and shall not use such information for any purposes other than within the scope specified by us.

We will only instruct a third party to process your personal information on our behalf where we have obtained the necessary assurance that they will properly manage and protect your information to the required standards under applicable laws. Moreover, before we provide and disclose your personal information to such service providers we require, by way of a written contract or similar means, assurance they will process this data strictly in compliance with our instructions and agreed terms of use including appropriate measures to properly handle personal information. We periodically verify their ongoing compliance with these obligations.

How long we keep your information

To provide your product or investment, and meet our legal and regulatory obligations, we keep your personal information and copies of records we create (e.g. calls with us) while you are a client or customer of ours. 

Even when you no longer have a relationship with us, we are required to keep information for different legal and regulatory reasons. The length of time will vary and we regularly review our retention periods to make sure they comply with all laws and regulations.

At the end of the applicable retention period, personal data must either be erased or anonymized. In some cases, no action will be required if data cannot be allocated to an identifiable person at the end of the retention period.

Your rights under law

You have a number of rights under data protection laws which may be exercised in certain circumstances. These are:

1. Right to Withdraw Consent

You have the right, may at any time, to withdraw any consent given, or deemed to have been given under the Personal Information Protection Law, in respect of the collection, use or disclosure of your personal data. We will then process your request within a reasonable time.

2. Right to Access and Correct

Individuals have the right to access and obtain a copy of their personal information upon request. You may request to correct or rectify any error or omission related to your personal data. We will then process your request within a reasonable time.

3. Right to Transfer

Individual have the right to request to transfer their personal information to their designated processors of personal information if their requests fulfil the conditions stipulated by the state cyberspace authorities. We will then process your request within a reasonable time.

4. Right to Restrict and Refuse

Upon request, individuals have the right to restrict and refuse the processing of their personal information by other, except when laws or regulations stipulate otherwise.

5. Right to Erasure

Upon request of erasure of individual’s personal information, we will process your request within a reasonable time.

If you wish to exercise any of your rights under law, please notify us using our contact details below.

How to contact us

If you have any questions about our Privacy Notice or the information we collect or use about you, please contact us:

FAO Data Protection Officer
abrdn Private Fund Management (Shanghai) Company Limited
Shanghai Huangpu District,
233 Taicang Road,
Xinmao Building 1901- 1903
Shanghai, 200020
Email: APAC.DPOffice@abrdn.com
Tel: + 86 21 5152 5600

How to make a complaint

We will always strive to collect, use and safeguard your personal information in line with data protection laws. If you do not believe we have handled your information as set out in this Privacy Notice, please let us know immediately and we will do our utmost to make things right.

While we hope that we can resolve any complaints for you, you do have the option complain to your local data protection authority e.g. Cyberspace Administration of China (CAC). This is available to you whether or not you have exhausted our complaints procedure. 

You can contact the Office of the Cyberspace Administration of China (CAC) at the following website:
http://www.cac.gov.cn/hdzx/jbzx/A091102index_1.htm