Last updated and effective date: 30 September 2026.
1. Who We Are and the Scope of This Policy
上海井畅企业管理咨询有限公司 (referred to as “we”, “us” or “our”) operates the Empact China website (empact.cn). We respect your privacy and process and protect personal information in accordance with applicable laws and regulations, including the Personal Information Protection Law of the People's Republic of China.
This Policy explains how we collect, use, retain and protect your personal information when you browse this website, submit a business enquiry or job application, or communicate with us about these matters. It also explains how you can exercise your rights.
If registration for a programme, volunteer recruitment, participation in an event or another service involves processing not described in this Policy, we will provide a separate notice before collecting the information. Websites and platforms independently operated by other Empact entities or third parties are subject to their own privacy notices.
You do not need to register or provide contact details to browse public pages. Reading this Policy, browsing the website or submitting an enquiry does not mean that you consent to marketing communications, public disclosure of your personal information or its provision to recipients outside mainland China.
2. What Is Personal Information?
Personal information is information recorded electronically or otherwise that relates to an identified or identifiable individual. It does not include anonymised information.
Names, telephone numbers and email addresses, as well as work contact details, job titles and access records that can be linked to an individual, may constitute personal information. Information being publicly available or used for business contact does not mean that it may be collected, used or shared without restriction.
Anonymisation means processing information so that a specific individual cannot be identified and the process cannot be reversed. Merely removing names, assigning reference numbers or hashing information does not necessarily take it outside the scope of personal information protection.
3. Information We Collect and How We Use It
We follow the principles of lawfulness, fairness, necessity and good faith. The information we process depends on the features you use.
- Browsing the website: IP address, access time, requested URL, browser information and necessary error records supplied through browser and network requests; Delivering pages, troubleshooting and maintaining operations and security; processed by servers and related network services.
- Online business enquiries: Your selected business area and service, name or preferred form of address, contact details (email, telephone or WeChat ID), enquiry and confirmation of consent; optional organisation and job title; Receiving and assigning enquiries, understanding your needs and responding or following up; emailed to the responsible staff after successful submission.
- Job applications: Your selected position, name, contact email, relevant experience, availability, and any other contact details, CV or portfolio links you provide; Assessing and contacting you about the current application; emailed to the recruitment lead.
- Direct communications: Information you provide through our published email address or other contact channels, communication content and necessary correspondence records; Responding to requests, verifying details and completing the follow-up you request.
- Preventing misuse and duplicate submissions: Hashed IP address, submission identifier and content digest for enquiry requests; Limiting repeated requests and preventing duplicate messages; these deduplication records do not contain the enquiry text or contact details in plain text.
Required fields in the enquiry form support receipt and response. Optional fields provide additional context; leaving them blank does not prevent a general enquiry. Job applicants must provide at least one CV or portfolio link. Without information necessary for assessment, we may be unable to process the application, but you can still browse the website. The relevant page indicates whether a submission feature is available.
Please provide only information relevant to the matter. Our general enquiry and application forms do not require identity document numbers, bank account details, health information, religious beliefs or other unrelated sensitive information. Before providing someone else's information, please ensure that you have a lawful basis. If a particular service requires sensitive personal information, we will separately explain why it is necessary, its implications for your rights and interests, and the safeguards we use, and obtain separate consent or other authorisation as required by law.
We process enquiry and application information after obtaining your consent as required by law. We may also process information within the necessary scope where the law permits or requires it, such as to enter into or perform a contract to which you are a party or to fulfil a legal obligation. If the purpose, method or categories of consent-based processing change, we will provide a new notice and obtain renewed consent as required by law.
4. Event Notices and Marketing Communications
We may contact you about an enquiry, application or request you have made, for example to answer questions, arrange an interview or update you on progress.
Before sending event promotions, newsletters or other marketing unrelated to the current matter, we will separately obtain the necessary consent and provide a convenient way to decline or unsubscribe. Declining marketing does not affect your ability to browse the website or use services unrelated to marketing.
5. Who May Access Your Information
We allow staff to access personal information only as necessary to handle the relevant matter and within their responsibilities. We do not sell your personal information.
- Internal staff responsible for enquiries: Enquiry contact details, enquiry content and cooperation details you provide; Receiving, assigning and following up on enquiries.
- Recruitment lead and necessary internal assessors: Application information and related correspondence; Assessing the current application and contacting the applicant.
- Entrusted website hosting, maintenance and email service providers: Access records, submissions or email information necessary for the relevant service; Supporting website operations and email delivery; processing scope, duration and security responsibilities are agreed as required by law, and performance of these obligations is supervised.
- Authorities legally entitled to request information: Necessary information within the scope of a lawful request; Fulfilling legal obligations, verifying the request and limiting disclosure to the necessary scope.
If we need to provide information to another independent personal information processor, including another Empact entity or programme partner for a specific collaboration, we will first inform you of the recipient's name and contact details, the purposes and methods of processing and the categories of information, and obtain separate consent as required by law, unless otherwise provided by law. Being an affiliate or partner does not give an organisation unrestricted use of your information.
We will obtain separate consent or have another lawful basis for public disclosure of personal information. If information must be transferred because of a merger, division, dissolution or similar event, we will notify you of the recipient as required by law and require it to continue fulfilling the relevant protection obligations. If the recipient changes the original processing purposes or methods, it must obtain renewed consent as required by law.
6. Retention, Cross-border Provision and Security
Personal information collected and generated within the scope of this Policy is stored within the People's Republic of China (for the purposes of this Policy, excluding the Hong Kong Special Administrative Region, the Macao Special Administrative Region and Taiwan).
We retain personal information for the shortest period necessary to fulfil the processing purposes, unless laws or administrative regulations prescribe a different retention period.
- Enquiries and correspondence: the period is determined by the time needed to respond, complete the follow-up you request and fulfil relevant legal obligations. Once the matter is closed and retention is no longer necessary, the information is deleted or anonymised.
- Job applications: the period is determined by the time needed to complete assessment, contact and related handling for the current recruitment process. When the purpose has been fulfilled and there is no legal retention requirement, the information is deleted or anonymised. If we wish to retain it separately for future vacancies, we will provide a separate notice and obtain the necessary consent.
- Website operational and security records: the period is determined by troubleshooting and security needs and applicable legal retention requirements. On expiry, the information is deleted or anonymised as required by law.
- Temporary enquiry rate-limiting and deduplication records: these remain valid for 15 minutes and 24 hours respectively. Expired records are no longer used for the corresponding checks and are cleared during subsequent requests. These in-memory records are managed separately from messages in the receiving mailbox.
A general enquiry or application does not authorise provision of personal information outside mainland China. If an international programme or cross-border collaboration requires provision to an overseas recipient, or access from overseas to information held in mainland China, we will first explain the recipient's name and contact details, processing purposes and methods, information categories and how to exercise rights with that recipient. We will obtain any separate consent required by law and complete the applicable data export procedures.
We use measures such as encrypted transmission and access controls to prevent unauthorised access, disclosure, alteration or loss. No technology can guarantee absolute security; this does not exempt us from our legal responsibility to protect information.
If personal information is or may be leaked, altered or lost, we will immediately take remedial measures, report as required by law and notify affected individuals as required of the circumstances, potential effects, measures taken and contact details.
7. Cookies, Similar Technologies and External Links
Under the website's current functionality, public pages do not integrate third-party advertising trackers or website analytics SDKs, and browser local storage is not used to build visitor profiles. Administrative login for authorised personnel may use cookies necessary for session management and security. You can manage or clear cookies through your browser; disabling necessary cookies may affect the relevant functions.
If we introduce non-essential analytics or marketing cookies or similar technologies, we will explain their purposes, the information involved and relevant service providers before activation, and obtain consent as required by law.
This website may link to ChatCircle, social platforms, partner websites or other registration platforms. Please read their privacy notices before using those services and submitting information. We remain legally responsible for our own processing activities.
8. Your Rights and How to Exercise Them
Subject to applicable law, you may learn about and request explanations of our processing rules; request access to, copies of, correction, supplementation or deletion of personal information; restrict or refuse relevant processing; withdraw consent; and request transfer of personal information where the legal conditions are met.
Please email maggie.yang@empact.sg, preferably with the subject “Personal Information Request”, briefly describing your contact channel, the relevant matter and your request. We may ask for information necessary to verify your identity to avoid releasing information to another person. Please do not send complete identity documents or unrelated materials without being asked.
We will accept requests promptly and, following any necessary identity verification, process and respond to them in accordance with the law. We will not impose unreasonable conditions on reasonable requests. If we cannot fulfil a request, we will explain the reasons and available remedies. You may also complain to an authority responsible for personal information protection or seek relief through the courts in accordance with the law.
Withdrawal of consent does not affect the validity of consent-based processing carried out before withdrawal, but may prevent us from continuing services that depend on the information. If a statutory retention period has not expired or deletion is technically difficult, we will cease processing other than storage and necessary security protection.
9. Information About Minors
Some programmes featured on this website are intended for young people, but the general enquiry form is not a child registration or sensitive information collection channel. For children under 14, a parent or other guardian should enquire on their behalf and avoid including the child's personal information in a general enquiry. Other minors should use relevant services under a guardian's guidance.
If a particular programme requires personal information about children under 14, we will establish specific processing rules, obtain consent from a parent or other guardian and apply strict safeguards. Information collected without appropriate authorisation will, following verification, be deleted or otherwise protected as required by law. Guardians may contact us at the email address in this Policy.
10. Changes to This Policy
We will update this Policy to reflect legal requirements, website features and our actual processing practices, and indicate the revision and effective dates. Material changes affecting your rights will be prominently notified. Where renewed consent is legally required, we will obtain it.
11. Contact Us
Personal information processor: 上海井畅企业管理咨询有限公司
Email: maggie.yang@empact.sg
Address: Room 1609, Block B, Yuehong Plaza, 88 Hongcao Road, Shanghai, China
Please also refer to the Terms of Use for the rules governing use of the website.