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PRIVACY AND PERSONAL INFORMATION PROTECTION POLICY

Effective date: October 19, 2018

Last updated: Nov 1, 2021

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CGPO2O ("us", "we", or "our") operates the CGPO2O.com and the CGPO2O.cn website
and offers human resource service (the “Service").

We offer services to those groups or persons who intend to recruit talents or
look for jobs. To use our Service, you may either browse and register an account
on the aforesaid site or contact us by phone, via e-mail, or via WeChat or other
instant messengers to request service from us.

This page informs you of our policies regarding our processing of your
information when you use our Service.

We understand the importance of your personal information to you and will do our
best to ensure the security and reliability of your personal information. We are
committed to maintaining your trust upon us and to protecting your personal
information pursuant to the following principles: legality, properness,
necessity and good faith principles, and openness and transparency principles.

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Please carefully read and understand this Privacy and Personal Information
Protection Policy prior to using our Service. You may use our Service only after
acknowledging that you have fully understood and agree to this Policy. By using
our Service, you accept and recognize the contents of this Policy and agree with
us to process your personal information in accordance with this Policy. 

If you do not accept all terms of this Privacy and Personal Information
Protection Policy, please do not continue to complete the account registration
process. Even if you do not register an account on our Service, you may
nonetheless use our Service, other than the job referral and other services we
provide for those employees who have registered accounts on our Service based
upon their personal information.

This Policy is intended to inform you of the followings:

 * Rules for Processing of Personal Information 
 * Rules for Processing of Sensitive Personal Information 
 * Rules for Cross-border Transfer of Personal Information 
 * Your Rights in Personal Information Processing Activities
 * How We Update this Policy
 * How to Contact Us

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Unless otherwise defined in this Policy, terms used in this Policy have the same
meanings as in our Terms and Conditions, accessible from CGPO2O.com or
CGPO2O.cn.

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Information Collection

While you are using our Service, we may ask you to provide us with the following
personal information:

 * Email address. Depending upon your need for communication online, we may
   request you to provide us with an e-mail address via which we can send
   updated Terms and Conditions, this Privacy and Personal Information
   Protection Policy and other documents to you.
 * First name and last name. To use our Service, you are required to complete
   real-name authentication to prove that you are a user of our recruitment or
   human resource management service who complies with the laws and regulations.
 * Phone number. We will send a non-binding interview request to you according
   to the actual progress of the recruitment process, connecting you with the
   employer. In order to facilitate our communication, we need you to provide us
   with a commonly used phone number.
 * Personal information in Registration Data. In registering for an account on
   our site, you are required to provide your personal information or resume as
   prompted by the Service registration form (“Registration Data”), and are also
   required to maintain and promptly update the Registration Data. You may also
   provide us with your personal information or resume by phone, via e-mail, or
   via WeChat or other instant messengers. Based on this information, we will
   recommend the jobs suitable for you to finally satisfy your service request.
   You can hide your personal information (including name, phone number, e-mail
   address, etc.) using the “Hide” function provided on our site.
 * Cookie. In order to facilitate your use of our site and Service, we will use
   Cookie as identity marker to help count the number of visits to our site,
   etc. You can choose to delete Cookie or set your browser to prevent Cookie
   function.
 * Usage data. We may also collect information about how the Service is accessed
   and used. This usage data may include information such as your computer's
   Internet Protocol address (e.g. IP address), browser type, browser version,
   the pages of our Service that you visit, the time and date of your visit, the
   time spent on those pages, unique device identifiers and other diagnostic
   data. Such usage data is not information related to identified or
   identifiable natural persons.

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Information Use

We will use the personal information we collect about you for the purposes of
providing and maintaining our Service, including for communicating with you
about the contents of our Service, notifying you about changes to our Service,
allowing you to participate in interactive features of our Service when you
choose to do so, providing customer care and support, monitoring the usage of
the Service, providing analysis or valuable information so that we can improve
the Service, and detecting, preventing and addressing technical issues.

You agree and authorize that we may provide your processed personal information
(mailing address, name, phone number, etc.) to those employers that may be
interested in employing you together with your resume and job objective. Of
course, you can withdraw this consent at any time upon written notice to us.

Your personal information on our site is confidential. In such case, all
employers on our site cannot search for and have access to your personal
information.

You agree that based on our needs for data statistic and industry research, we
may process the data including your information on our site according to the job
opportunities posted by employers or the job objectives of employees, etc.

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Tracking & Cookies Data

We use cookies and similar tracking technologies to track the activity on our
Service and save certain information.

Cookies are files with small amount of data which may include an anonymous
unique identifier. Cookies are sent to your browser from a website and stored on
your device.

Tracking technologies also used are beacons, tags, and scripts to collect and
track information and to improve and analyze our Service.

You can instruct your browser to refuse all cookies or to indicate when a cookie
is being sent. However, if you do not accept cookies, you may not be able to use
some portions of our Service.

Examples of Cookies we use:

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Session Cookie - We use Session Cookies to operate our Service.

Preference Cookie - We use Preference Cookies to remember your preferences and
various settings.

Security Cookie - We use Security Cookies for security purposes.

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Information Transfer

If you are located outside China and choose to provide information to us, please
note that we may transfer the personal information to China and process it
there. Your consent to this Policy followed by your submission of such
information represents your agreement to that transfer.

We will within our service system take all necessary steps reasonably  to ensure
that your data is treated securely and in accordance with relevant policies.

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Cross-border Transfer of Personal Information

Our overseas affiliates or prospective foreign employers (collectively,
“Overseas Recipients”) may need you to provide your personal information so as
to find you on our site or directly get in contact with you. If you agree that
your personal information may be available to an Overseas Recipient for
processing, we will contact you to give a separate consent when necessary (and
if you proactively apply for a job opportunity posted by an overseas person on
our site, then you will be deemed to have agreed with us to provide your
personal information to such overseas person), and inform you of the name and
contact info of such Overseas Recipient, the purpose and method of its
processing, the type(s) of personal information to be processed by it, as well
as the method and procedures in which you may exercise your rights hereunder
against it, etc.

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We will complete evaluation of the security of cross-border transfer of personal
information to obtain the corresponding permit and properly manage such transfer
strictly in accordance with the requirements set forth in the relevant laws and
regulations. In addition, we will enter into a contract or other legally binding
document regarding the cross-border transfer of your personal information with
each Overseas Recipient of your personal information, assess the possible
security risks of such transfer and evaluate the protective measures taken to
address such risks, and take necessary steps to ensure that Overseas Recipients
process your personal information in compliance with the personal information
protection standards set out in the relevant applicable laws and regulations.

If you use our site or Service to provide your personal information to an
employer, and such employer is a multinational corporation or uses your personal
information outside China, then you must have understood and agree to the
personal information protection policy of such employer when providing your
personal information to it. In no event will we be liable for any personal
information security incidents that may result from said act.

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Information Storage

Unless otherwise required by the laws and regulations, we will keep your
personal information while you are using our Service. Your personal information
will be stored and backed up in our server, and if we need to transfer your
personal information to any individual, organization or country outside China,
then we will ensure that such individual, organization or country treats your
personal information in accordance with the relevant applicable laws and
regulations.

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Disclosure of Information

We will cooperate with competent authorities as required by law by disclosing
your personal data when necessary to: 

 * To comply with a legal obligation
 * To protect and defend the rights or property of CGPO2O
 * To prevent or investigate possible wrongdoing in connection with the Service
 * To protect the personal safety of users of the Service or the public
 * To protect against legal liability

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Without your permission, we will not disclose your personal information to
employers. Your full name, contact info, or current employer will only be shared
if and after you indicate that you are interested in an employer and the related
job opportunity.  

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We will not disclose any information about you to your current employer, that
shall not check any of your details on our site.

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We strive to use commercially acceptable means to protect your personal
information from unauthorized disclosure. But remember that since no method of
transmission over the Internet, or method of electronic storage is 100% secure,
we will not be liable for any disclosure of your personal information which is
attributable to technical reasons, other than man-made causes.

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Service Providers

You agree that we may employ third party companies ("Service Providers") to
facilitate our Service, to provide the Service on our behalf, to perform
Service-related services or to assist us in analyzing and monitoring how our
Service is used.You agree and acknowledge that when we retain a third party
individual to perform the Service for you, we will inform you through our site
or by other means of the name and contact information of such third party
individual, the purpose and method of its processing, and the type(s) of
personal information to be processed by it. If you do not agree with such third
party to obtain or process your information, please notify us in an express
manner. If, within 5 business days following the giving of our notice, you do
not expressly reject or agree to the processing of your personal information by
such third party, then you will be deemed to have agreed to such processing.
However, you have the right to reject such processing or withdraw such deemed
consent at any time (but such rejection or withdrawal will not invalidate all
personal information processing activities previously conducted based on such
deemed consent).

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We will agree with each Service Provider upon, amongst others, the purpose,
period and method of the contract processing, the type(s) of personal
information to be processed by the Service Provider, the protective measures to
be taken by the Service Provider, as well as our respective rights and
obligations in relation to the contract processing according to law, and will
monitor the personal information processing activities performed by the Service
Providers.

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You agree that these third party Service Providers may process your personal
data within the scope of said agreement.

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Service Providers use the following analytics:

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 * Mixpanel




Mixpanel is provided by Mixpanel Inc.







You can prevent Mixpanel from using your information for analytics purposes by
opting-out. To opt-out of the Mixpanel service, please visit this page:
https://mixpanel.com/optout/




For more information on what type of information Mixpanel collects, please visit
the Terms of Use page of Mixpanel: https://mixpanel.com/terms/ 




 * Google Analytics




Google Analytics is provided by Google LLC.




You can prevent Google Analytics from using your information for analytics
purposes by opting-out. To opt-out of the Google Analytics service, please visit
this page: https://tools.google.com/dlpage/gaoptout. 







For more information on what type of information Google Analytic collects,
please visit the Terms of Use page of Google Analytics:
https://marketingplatform.google.com/about/analytics/terms/us/#:~:text=Google%20Analytics%20Terms%20of%20Service&text=BY%20CLICKING%20THE%20%22I%20ACCEPT,THE%20OWNER%20OF%20THIS%20ACCOUNT 




 * Hotjar




Hotjar is provided by Hotjar Limited.




You can prevent Hotjar from using your information for analytics purposes by
opting-out. To opt-out of the Hotjar service, please visit this page:
https://www.hotjar.com/legal/compliance/opt-out/




For more information on what type of information Hotjar collects, please visit
the Terms of Use page of Hotjar:
https://www.hotjar.com/legal/policies/terms-of-service/.

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Information Deletion

You have the right to withdraw all personal information you have posted on our
site, or to send a request for deleting your information to us. Upon receipt of
such request, we will immediately commence the deletion of your personal
information, at which time you may no longer be able to use certain portion of
our Service. The withdrawal of your consent does not invalidate our personal
information processing activities previously conducted based upon your consent.

We will retain or delete your personal information for a certain time period as
required by the laws and regulations of China.

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Links to Other Sites

Our Service may contain links to other sites that are not operated by us. If you
click on a third party link, you will be directed to that third party's site.

We strongly advise you to review the Privacy and Personal Information Protection
Policy of every site you visit prior to using the service offered or submitting
your personal information on that site. If you do not agree to such policy,
please do not submit any information on such site and log out and refrain from
using any service offered on it.

We have no control over and assume no responsibility for the content, privacy
and personal information protection policies or practices of any third party
sites or services.

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Your Rights

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In accordance with the relevant laws, regulations and standards in China, as
well as the customary practices in other countries and regions, we assure that
you can exercise the following rights in respect of your own  personal
information: 

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To access, inquire about and copy your personal information

You have the right to access, inquire about and copy your personal information,
unless otherwise provided by law.

To exercise this right, you may use our Web form to contact us or send us e-mail
at any time, and we will make a response to your request for access within 30
days following our receipt thereof. 

We will also satisfy your request for access to any other personal information
generated during your use of our products or Service, provided that the
provision of such other personal information will not require us to make
excessive efforts. If you intend to exercise the right to be informed about
data, please notify us of your intention via e-mail.

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To correct and supplement your personal information

If you find any error in our processing of your personal information, you have
the right to require us to make correction and supplement. You can make a
request for correction or supplement to us. 

To exercise this right, you may use our Web form to contact us or send us e-mail
at any time, and we will make a response to your request for correction or
supplement within 30 days following our receipt thereof.

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To delete your personal information

You can make a request for deletion of your personal information to us if:

 * we process your personal information in violation of the laws and regulations
   or in violation of our agreement;
 * we collect and use your personal information without obtaining your consent;
 * we cease to offer the Service, or the retention period for your personal
   information has expired; 
 * you cease to use our products or Service, or you close your account on our
   site, or you withdraw your consent to our processing of your personal
   information; or
 * the purpose of processing has been achieved or has become unable to be
   achieved, or your personal information is no longer necessary for the
   achievement of the purpose of processing.

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We will respond to your request for deletion and at the same time, will notify
all entities to which we have disclosed your personal information of such
request, requiring them to promptly delete your personal information, unless
otherwise provided in the applicable laws and regulations or except when any
such entity has obtained a separate authorization from you.

It is possible that we may not delete any information from our back-up system
immediately after you have removed such information from our Service, but we
will delete such information when updating the back-ups next time.

 * To change the scope of your consent：Each business function needs certain
   basic personal information. For the collection and use of additional personal
   information, you may give or withdraw your consent at any time.
 * To close your account on our site： You can close your account previously
   registered on our site at any time. You may either follow the account
   cancellation process described on our site to close your account by yourself
   or contact us to close your account. Once your account has been closed, we
   will cease to provide any products or services for you and will delete your
   personal information upon your request, unless otherwise provided in the
   applicable laws and regulations.
 * Response to said requests：For the sake of security, you may be required to
   submit a written request or prove your identity in other ways. We may need to
   verify your identity before handling your request. We will provide a response
   to you within 30 days after verifying your identity.

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In principle, we do not charge any fees for your reasonable requests, but will
charge certain costs and fees for your repeated requests or your requests
exceeding a reasonable limit where appropriate. We may reject your request that
is unreasonably repetitive or requires excessive technological means (e.g.
requiring development of new systems or substantial change to the current
practices) or brings about risks against the legitimate rights and interests of
others or is quite unrealistic (e.g. involving any information stored in back-up
tapes). 

We will be unable to respond to your request if:

 * such request concerns the performance by the controller of related personal
   information of the obligations set out in the applicable laws and
   regulations; 
 * such request is directly related to the state security and national defense
   security; 
 * such request is directly related to the public security, public health and
   material public interests;
 * such request is directly related to criminal investigation, prosecution,
   trial and enforcement of judgment, etc.;  
 * the controller of related personal information presents sufficient evidence
   that the subject of such personal information has made such request with
   subjective malice or is abusing his right by making such request;
 * we decide not to respond to such request with a view to safeguarding the
   material legitimate rights and interests of the subject of related personal
   information or of other individuals, but it is difficult for us to obtain the
   consent of the subject of related personal information to us doing so; or 
 * our response to such request would result in the legitimate rights and
   interests of the subject of related personal information or of other
   individuals or organizations being materially damaged, or would involve trade
   secrets.

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Sensitive Personal Information and Protection of Minors

We do not process your sensitive personal information and you are advised not to
publish your sensitive personal information on our site, including your
biometric data, the information about your religious belief, particular
identity, medical care and health, financial accounts and whereabouts,etc., as
well as the personal information of minors under the age of 14.

Our Service does not address anyone under the age of 18. We do not knowingly
collect personal information from anyone under the age of 18. 

If you are a parent or guardian and you are aware that your children have
provided us with personal information, please contact us.

If we become aware that we have collected personal data from minors, we take
steps to remove that information from our servers.

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Change to and Interpretation of this Policy, and Choice of Law

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We may update our Privacy and Personal Information Protection Policy in due
course. 

We will notify you of any change by posting the new Privacy and Personal
Information Protection Policy on this page. You are advised to review this
Policy periodically for any changes.

We will let you know via email and/or a prominent notice on our Service, prior
to the change becoming effective and update the "effective date" at the top of
this Privacy Policy.

We have and reserve the right to provide a final interpretation of this Policy. 

This Policy shall be governed by and construed in accordance with the laws of
the jurisdiction where Beijing Cornerstone Consulting Co., Ltd. was
incorporated, and in the event of a conflict of law or a dispute over the
application of law, such laws shall prevail. Any change to this Privacy Policy
shall be effective upon being posted on this page. 

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Contact Us

If you have any question or requirement about this Privacy and Personal
Information Protection Policy, please contact us at the following contact
details: 

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Personal Information Protection Principle

privacy@cgptalent.com

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or by visiting this page on our website: https://www.cgpo2o.cn/en/#contact-us

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CGP O2O Talent Marketplace
Email us at info@cgptalent.cn or send us a request through our Contact page.

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