Privacy notice Wikborg Rein in China
This privacy notice was last updated 24 March 2023. In this privacy notice, you will find information about how we process your personal information. The purpose of the notice is to provide you with information about Wikborg Rein Advokatfirma AS, through its representative office in China (Wikborg Rein Advokatfirma AS Shanghai Representative Office) ("Wikborg Rein" or "we") responsibility for processing as a personal information processor, and the rights you have as a data subject (section 1). The privacy notice applies to our processing of personal information related to assignments of legal assistance and services (section 2.1), marketing activities (section 2.2), social media (section 2.3), recruitment (section 2.4) and use of wr.no (section 2.5).
1.1 Wikborg Rein's responsibility for processing
Wikborg Rein Advokatfirma AS, through its representative office in China (Wikborg Rein Advokatfirma AS Shanghai Representative Office) is committed to processing your personal information in a safe and secure manner, and in line with Personal Information Protection Law of the People's Republic of China ("PIPL"). Personal information refers to any kind of information related to an identified or identifiable natural person as electronically or otherwise recorded, excluding information that has been anonymized.
We act as personal information processor for the personal information that we process about clients, contact persons at clients and other parties, contact persons at collaborators and suppliers, participants at events, recipients of newsletters, users of wr.no and services, job seekers and visitors to our pages on social media (collectively, the "data subjects").
1.2 Your rights as a data subject
As a data subject you have, with certain reservations, the right to:
- request confirmation from Wikborg Rein as to whether or not personal information concerning you are being processed, and, where that is the case, access to the personal information and information about the processing of personal information;
- request any inaccurate personal information about yourself to be rectified without undue delay, and to have incomplete personal information completed;
- request the erasure of your personal information;
- request Wikborg Rein to restrict the processing of your personal information;
- obtain from Wikborg Rein a copy of personal information concerning you that you have provided to us and request the transfer of these data to another processor without Wikborg Rein's hindrance;
- object to the processing of personal information concerning you;
- withdraw your consent given to us for the processing of your personal information.
As a law firm, however, we are subject to strict legal requirements, including confidentiality and archiving obligations, which can and will limit your above-mentioned rights as a data subject.
To exercise your rights, you can contact us, see section 1.4.
1.3 Changes to the privacy notice
We may update this privacy notice due to changes in the law or in our practices or when necessary for other reasons. You should, therefore, familiarize yourself with the content of the privacy notice at regular intervals.
1.4 Contact us
If you have questions about how we process your personal information, wish to exercise your rights mentioned above in section 1.2 or have other inquiries, you are welcome to contact us.
2 When do we process your personal information?
2.1 Assignments of legal assistance and services
2.1.1 Our processing of personal information
When Wikborg Rein carries out assignments of legal assistance and delivers legal services, we are the personal information processor for all personal information we process in this context. Data subjects are clients and their contact persons, parties and other third parties who are referred to in case documents. About these, we typically collect the following categories of personal information:
- Contact information such as name, address, job title and other contact information.
- Identification documents.
- Billing and payment information.
- Case information, various information about individuals with connection to the case, including counterparties.
In some assignments of legal assistance, we process special categories of personal information (e.g., in insurance and employment law cases) and information about criminal convictions and offences (e.g., in cases about financial crime.
2.1.2 Purpose and basis of the processing
We process personal information based on data subject’s consent. Please note that data subject can withdraw such consent anytime by contacting us via e-mail (please see contact details in section 1.4 above).
2.1.3 Sharing of personal information with third parties and transfer of personal information
Lawyers have a duty of confidentiality regarding all information they gain access to in connection with legal practice, and all employees of Wikborg Rein are subject to a duty of confidentiality. Within the framework of the duty of confidentiality, we share information when it is necessary to fulfill statutory requirements or for the operation of the law firm with, among others, the following actors:
- Counterparties, witnesses, other involved parties, courts or public bodies, for example supervisory authorities.
- Our suppliers of IT and administrative services, for example systems for communication, case management, document processing, KYC/Client onboarding, ERP, IT infrastructure and operation. We always enter into necessary data processing agreements with suppliers when these process personal information on behalf of Wikborg Rein.
If the circumstances of the case require it, we may transfer your personal information to jurisdictions, regions and countries outside China for example to our offices in Oslo, Bergen, London and Singapore. For the sake of good order, it is noted that we have separate systems in the various countries, and documentation from a case in China will therefore not be given access outside China unless the circumstances of the case require it. Where the sharing of personal information with third parties involves the outbound transfer of personal information, we ensure that the personal information is afforded a level of protection that is equivalent to that guaranteed within China, including by entering into agreements based on the Chinese standard contractual clauses and by implementing relevant supplementary measures.
2.1.4 Retention and deletion
We retain your personal information as long as we have an ongoing legitimate business need to do so, which includes but not necessarily limited to providing services or products to you, or as required or permitted by applicable laws, such as tax and accounting laws.
When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize your personal information. In the situation where we are not able to delete your personal information, we will securely store your personal information and isolate it from any further processing until deletion is possible.
We will also delete your personal information if our processing is based on your consent and you exercise your right to withdraw the consent.
2.2 Marketing and events
2.2.1 Our processing of personal information
We collect personal information in connection with marketing, courses, seminars, other events and newsletters, as well as other information about our services and activities, and to answer inquiries. Data subjects are employees of our clients, participants in events and others who sign up for our newsletter or otherwise approach us with an enquiry. In this respect, we process personal information such as:
- Basic contact information such as name, e-mail address and phone number.
- Job title and place of work, possibly year of study and place of study for students.
- Allergies and food preferences if we serve food at our events.
- Areas of interest when you tick which areas of interest you wish to receive newsletters about.
- Picture(s) of participants if we take pictures or videos at events etc.
- Other information that we receive when someone makes an inquiry, or which is necessary to follow up on such inquiries.
2.2.2 Purpose and basis of the processing
- Marketing inquiries, newsletters and invitations to events. We send information to clients and other parties concerned to follow up, to inform about news and our services and to invite to events. We obtain your consent before we send you marketing-related information. More information about our newsletter, how to sign up, unsubscribe etc.
- Registration for events. In connection with registration for our events, you will need to provide your consent of our processing of your personal information in order for us to manage and plan the event.
- Publication of photos and videos. In those cases where we take photos or videos at events organised by Wikborg Rein, we follow Article 1019 of the Civil Code of the People's Republic of China on the right to one's own photos before we publish any photos. We will, therefore, ask for consent before we publish a photo where a person, and not the event itself, is the main focus. If you have consented, but later wish to withdraw your consent, you can contact us via e-mail.
2.2.3 Sharing of personal information
220.127.116.11 Sharing of personal information with co-organisers for events
We carry out some events (seminars, lectures etc.) in collaboration with co-organisers. In such cases, we may share your contact information with co-organisers and these may send you newsletters and other marketing inquiries on behalf of Wikborg Rein. If you have given consent to receive newsletters and other marketing inquiries, the consent will also include the sharing of information with co-organisers.
If the circumstances of the markets and events require it, we may transfer your personal information to countries outside China. For the sake of good order, it is noted that we have separate systems in the various countries, and materials for marketing and events in China will therefore not be given access outside the China unless the circumstances of marketing and events require it. Where the sharing of personal information with third parties involves the transfer of personal information, we ensure that the personal information is afforded a level of protection that is equivalent to that guaranteed within China, including by entering into agreements based on the Chinese standard contractual clauses and by implementing relevant supplementary measures.
18.104.22.168 Use of sub-processors
In some cases, suppliers; for example IT suppliers, marketing companies, providers of customer satisfaction surveys, issuers of newsletters etc., will process personal information on our behalf. Wikborg Rein always enters into necessary data processing agreements in these cases.
2.2.4 Retention and deletion
We delete your personal information related to marketing and events when they are no longer necessary for the purpose for which they were collected. When we process personal information in relation to existing customer relationships, we delete these data when the customer relationship ceases to exist. When we process personal information in relation to events and seminars, we delete these data as soon as possible after the event. The personal information that we process on the basis of your consent to receive newsletters, we delete when you withdraw your consent.
2.3 Social media
2.3.1 Our processing of personal information
Wikborg Rein uses LinkedIn. We are joint information processor with LinkedIn. Data subjects are visitors to our company pages, whether the visit is done via a user account or other type of log-in function, or without such an account or log-in function.
Through these channels, we typically process the following personal information:
- Name, user name and other visible information about people who visit and interact with our pages on social media.
- Information we receive through your interaction with us, including through likes, comments and messages we receive on the various platforms.
- Other available information about browsing behaviour, preferences etc.
Please be aware that additionally, LinkedIn processes your personal information for their own purposes. Wikborg Rein is not responsible for LinkedIn's processing of personal information for their own purposes. You can limit LinkedIn's collection of personal information by changing the settings in your user account on the respective platforms. See LinkedIn's guidelines here.
2.3.2 Purpose and basis of the processing
We process personal information in relation to social media to provide information to and to communicate with users of our pages on social media. The legal basis for this is your consent before our processing of your personal information.
2.3.3 Retention and deletion
We delete your personal information when they are no longer necessary for the purpose for which they were collected. You can delete your personal information yourself on our social media or contact us and convey your wish to have the data deleted.
2.4.1 Our processing of personal information
We process personal information about job applicants and other potential candidates, including for positions such as permanent employees, trainees, law students writing their master's thesis etc.
The following data is processed in the recruitment of permanent employees, trainees, law students writing their master's thesis and other employees:
- Contact information such as name, e-mail address, postal address, phone number, job title, employer, place of study and year of study if this is relevant.
- Information about qualifications and interests such as diplomas/transcripts, application, CV, courses, references and information that you provide access to in connection with your application process and interview.
We also process the following information in connection with the recruitment and follow-up of trainees:
- Assessments and evaluations of the applicant which are carried out during traineeship.
2.4.2 Purpose and basis of the processing
The processing of personal information in the recruitment process is necessary to hire the best qualified candidate. If you become our employee, the basis for the processing is partly that the processing is necessary to enter into an employment agreement with employee and for carrying out human resources management under an employment policy legally established by us. If you have applied for a position with us or only been a trainee but have not been employed, we will, therefore, ask for consent before we process your personal information.
2.4.3 Sharing of personal information with third parties
In Wikborg Rein, only the HR department and others involved in the recruitment process, i.e. recruiting partners and members of the trainee committee for trainees, have access to information about you when you apply for a job with us. Our suppliers of systems for IT, HR and communication process personal information on our behalf. We always enter into necessary data processing agreements with these suppliers.
If the circumstances of the employment require it, we may transfer your personal information to countries outside China. For the sake of good order, it is noted that we have separate systems in the various countries, and your CV and employment information in China will therefore not be given access outside the China unless the circumstances of employment require it. Where the sharing of personal information with third parties involves the transfer of personal information, we ensure that the personal information is afforded a level of protection that is equivalent to that guaranteed within China, including by entering into agreements based on the Chinese standard contractual clauses and by implementing relevant supplementary measures.
For the employment purpose as set out herein, your personal information will be shared with the following legal entity for them to processing:
Shanghai Foreign Service (Group) Co., Ltd.
2.4.4 Retention and deletion
You can delete your personal information in CV at any time. It is your responsibility to delete your user profile, but applications are automatically deleted after 2 years if they are submitted after the start of 2022. 6 months after submitting an application, you will receive a reminder from CV that you have applications in the system, so that you can delete these if you wish.
Personal information about trainees is kept for 3 years after the last traineeship if the relevant candidate has consented to this. The reason for this is that the information may be relevant and necessary for later recruitment of the candidate in question. Evaluations and other surveys of trainees are stored in Netigate and deleted automatically after 3 years.
If you have applied for a position with us but have not been employed, we keep the information about you for 6 months after the position has been filled.
2.5 Users of wr.no
2.5.2 Purpose and basis of the processing
- Strictly necessary cookies. These are cookies we must use for the various services on our website to function. These are the only cookies we use that you cannot opt out of in our cookie banner.
- Functionality. These are cookies that help us store information that changes the way the website looks or behaves.
- Analysis and statistics. These are cookies that help us understand how visitors use our websites.
- Marketing. These are cookies that we use to track your activity across websites, in order to show you advertisements that are relevant and interesting to you.
More information about the purpose and retention period for each individual cookie can be found under "details" in our cookie banner by clicking the cookie symbol with arrows.
2.5.3 Retention and deletion
Information about the retention period for each individual cookie can be found under "details" in our cookie banner by clicking the cookie symbol with arrows.
2.5.4 Do you have questions?