Effective date: February 2, 2023

Zhong Lun Law Firm (“Zhong Lun” or “we”), with a registered address of 22-31/F, South Tower of CP Center, 20 Jin He East Avenue, Chaoyang District, Beijing, respects your privacy and is committed to protecting your personal information. This privacy policy will help you understand how we collect, process and protect your personal information when you visit our official website ( www.zhonglun.com  ) and attend any events we host, and how you may exercise your rights regarding your personal information.

If you have any question about this privacy policy, feel free to contact us at any time via:

• Tel: +86 10 5957 2288

This privacy policy will help you understand:

1. How we collect and use your personal information;

2. How we store your personal information;

3. How we commission third parties to process, provide to third parties or disclose to the public your personal information;

4. How we use cookies and similar technologies;

5. How we protect your personal information;

6. How we process the personal information of the underaged;

7. Your rights;

8. How this privacy policy is updated; and

9. How to contact us.

1. How do we collect and use your personal information

(1) Our website will collect and store necessary log information when you browse the website to fulfill our legal obligations.

(2) If you subscribe to Zhong Lun’s legal reports, featured articles, or monthly highlights, we will collect your name, the name of your organization, your position within the organization and your business email address that you voluntarily fill in to verify your identity and send you the materials you have subscribed to.

(3) If you sign up for any of our online or offline events, we will collect your name, the name of your organization, your position within the organization and you mobile number, business email address and way of participation that you voluntarily fill in to verify your identity and complete your registration.

Please note that if the information you provide to us contains any personal information of a person other than yours, you should make sure that you have the right to provide such information on behalf of that person and remind that person to read and consent to this privacy policy.

2. How do we store your personal information

(1) The personal information we collect and generate will be stored within the People’s Republic of China;

(2) We will only keep your personal information for the period required by law or for the shortest period necessary to fulfill the purpose of processing such information. Upon the expiration of such period, we will delete or anonymize your personal information.

3. How do we commission third parties to process, provide to third parties or disclose to the public your personal information

(1) Third-party processing

To complete subscription to contents and signing up for events, we may engage a third party to process your personal information on our behalf. We will require any third party engaged by us to process personal information to do so in compliance with this privacy policy and applicable laws and regulations.

(2) Provision of personal information to third parties

In principle, we will not provide your personal information to any other party. However, we may share your personal information with a business partner when we provide you with information services or host an event in cooperation with the business partner. In such case, we and the business partner will be co-processors of your personal information, and we will inform you of the name and contact details of the business partner as required by applicable laws and regulations and require the business partner to process your personal information in compliance with this privacy policy and applicable laws and regulations.

(3) Disclosure to the public

We will not disclose your personal information to the public, unless we acquire your separate consent thereto or we have any other legal basis to do so.

(4) Special circumstances for provision and disclosure of personal information

We may collect and use your personal information without your consent if such personal information:

(i) relates directly to China’s national security and national defense;

(ii) relates directly to public security, public health, significant public interests;

(iii) relates directly to any criminal investigation, prosecution, trial or judgement;

(iv) needs to be collected or used to protect the life, property or any other significant interest of the right holder of the personal information or any other person, provided that your consent to such collection or use is difficult to obtain;

(v) subjects to any other circumstance where the collection and use of the personal information is required under the applicable laws or regulations.

4. How do we use cookies and similar technologies

We use cookies and similar technologies to provide better user experience and optimize our services. Cookies are small data files that can be stored on your computer or mobile device to track your online activities and store information about your preferences.

You can choose to accept or reject cookies according to your preferences and modify the preferences on the access device. You can also delete cached data that has been stored locally by clearing your browser cache. Please note that disabling cookies may affect your experience on the Site.

5. How do we protect your personal information

We have implemented industry-standard security measures to protect the personal information you provide against unauthorized access, public disclosure, use, alteration, damage or loss of data. We will take all reasonably practicable steps to protect your personal information.

Please be aware and understand that the Internet is not a 100% secure environment, and we will endeavor to ensure or guarantee the security of any information you send to us. We will assume legal liability in the case that any of our physical, technical, or management or protective facilities is breached, resulting in unauthorized access, public disclosure, alteration, or destruction of information, which causes damage to your legal rights and interests.

In the unfortunate case of a personal information security incident, we will, in accordance with the requirements of laws and regulations, promptly inform you of the outline and possible impact of the security incident, the measures we have taken or will take to address the situation, the advice for you to independently prevent and reduce risks, and the remedial measures available to you. We will promptly inform you of the situation related to the incident by email, letter, phone call, push notification, etc. When it is difficult to inform the right holders of the personal information one by one, we will make a public announcement in a reasonable and effective way. At the same time, we will also take the initiative to report how we address personal information security incidents in accordance with the requirements of the regulatory authorities.

6. How do we process the personal information of the underaged

Please note that our information services and events are for adults only. If we find that we collect any personal information of an underaged person without verifiable prior parental consent, we will try our best to delete relevant data as soon as possible.

7. Your rights

If you wish to access, copy, revise, update or delete your personal information, you may contact us via the contact information provided in the “How to contact us” section below. We will respond to your request within 15 business days. To ensure security, we may kindly ask you to verify your identity before processing your request.

We generally do not charge fees, provided that your request is reasonable. However, if you run the same request for multiple times or your request is beyond reasonable extent, we may charge certain fees to cover our costs depending on the situation. We may reject a request that is repeated without proper cause, requires too much technological efforts, creates risks to others’ legitimate rights and interests or is impractical. We will not respond to a request that:

(i) affects our performance of any mandatory obligation under laws and regulations;

(ii) relates directly to national security or national defense;

(iii) relates directly to public security, public health, significant public interests;

(iv) relates directly to any criminal investigation, prosecution, trial or judgement;

(v) concerns the protection of the life, property or any other significant interest of the right holder of the personal information or any other person, provided that consent from such person is difficult to obtain;

(vi) will severely harm the legitimate interests of the right holder of the personal information or other individuals or organizations, if we accepted such request;

(vii) involves any trade secret.

8. How is this privacy policy updated

We may update this privacy policy when needed. We will publish the updated versions of this privacy policy on this webpage and notify you in a more noticeable way if any such update is significant (way of notification may include putting on special notice on the webpage to delineate the update). We will not reduce in any way your rights provided under this privacy policy without your express consent.

9. How to contact us

If you have any question with regard to our privacy policy or protection of personal information, you may contact us via:

• Tel: +86 10 5957 2288