PRIVACY NOTICE - MAINLAND CHINA PRIVACY SCHEDULE



This China Privacy Schedule supplements our General Privacy Notice and applies where the Personal Information Protection Law of the People’s Republic of China, together with applicable PRC data protection, cybersecurity and data security laws, applies to our processing of personal information.

For the purposes of this Privacy Schedule, “personal information”, “sensitive personal information”, “processing” and “personal information processor” have the meanings given under applicable PRC law.

Otherwise, unless defined herein, capitalised terms in this Privacy Schedule shall be as defined in our General Privacy Notice.  In particular, “Agency” and “Agency Group” refer to the specific agency, legal entity or group of entities responsible for the relevant processing, as described in the General Privacy Notice.

1. Personal information processor

The personal information processor responsible for your personal information will usually be the Agency Group entity with which you or your organisation has a relationship, or which operates the relevant website, event or service.

You may contact us at: DPO@the-independents.com

Please see our General Privacy Notice for details of the relevant local entity or representative. Where required by PRC law, other details will be provided separately.

2. Categories of personal information we process

We may process the following categories of personal information:

Category

Examples

Identity and contact information

Name, employer, job title, business address, email address, telephone number, social media/professional profile details

Business communications

Emails, messages, meeting notes, call notes, event interactions and professional correspondence

Profile and relationship information

Preferences, event attendance, interests, feedback, marketing preferences and relationship management notes

Technical and usage information

IP address, browser type, device identifiers, website usage data, cookie and analytics information

Compliance information

Information used for sanctions, anti-bribery, KYC, onboarding, supplier/client screening and related checks

Financial and transaction information

Invoicing details, payment information, purchase order details and transaction records

Other information

Information you or your organisation provide to us in the course of business

3. Purposes and methods of processing

We process personal information by electronic and, where necessary, manual means for the following purposes:

  • managing our business relationship with you or your organisation;
  • communicating with you;
  • providing or receiving services;
  • administering contracts, projects, accounts, procurement and payments;
  • organising and managing events;
  • conducting compliance, sanctions, anti-bribery, KYC and onboarding checks;
  • sending business updates, invitations and marketing communications, where permitted;
  • maintaining and improving our website, systems, services and operations;
  • managing group administration, reporting and internal business operations;
  • protecting our business, systems, staff, clients and partners;
  • managing corporate transactions, reorganisations or integrations; and
  • complying with legal, regulatory, tax, accounting and reporting obligations.

4. Sensitive personal information

We do not usually seek to collect sensitive personal information from business contacts.

Where we need to process sensitive personal information, we will do so only where there is a specific purpose and sufficient necessity, and where required by PRC law we will obtain your separate consent.

Sensitive personal information may include information such as identification documents, financial account information, precise location data, health information, biometric information or other information treated as sensitive under PRC law.

5. Sharing, entrusted processing and disclosure

We may share or entrust processing of your personal information with the categories of recipients described in our General Privacy Notice, including:

  • Agency Group and The Independents Group companies;
  • IT, hosting, CRM, email, marketing and system administration providers;
  • event partners and business partners;
  • professional advisers, including lawyers, auditors, insurers and accountants;
  • compliance screening providers;
  • regulators, courts, public authorities and law enforcement bodies; and
  • parties involved in corporate transactions, reorganisations or integrations.

Where required by PRC law, we will provide additional details and/or obtain separate consent before sharing your personal information with another independent personal information processor.

6. Cross-border transfers of personal information

Because we are part of an international group, your personal information may be transferred outside Mainland China to Agency Group entities, The Independents Group entities, clients, business partners and service providers in other jurisdictions, including the UK, EEA, United States, Hong Kong, Singapore, Japan, Korea, Switzerland, UAE and other countries in which we, our group companies, clients or service providers operate.

Where required by PRC law, we will implement an appropriate cross-border transfer mechanism, which may include:

  • obtaining your separate consent;
  • conducting a personal information protection impact assessment;
  • entering into the PRC standard contract for cross-border transfer of personal information;
  • completing a security assessment where required; and/or
  • applying other lawful transfer mechanisms recognised under PRC law.

Where required by PRC law, we will provide additional details of overseas recipients, including their name or category, contact details, country or region, processing purposes, processing methods, categories of personal information, retention period and how you may exercise your rights.

The table set out in the Appendix to this Privacy Schedule provides an overview of the categories of overseas recipients to whom personal information may be transferred. Where PRC law requires more specific details of named overseas recipients, these will be provided separately or on request, as required by applicable law.

7. Retention

We retain personal information only for the period necessary for the purposes described in this Privacy Schedule and our General Privacy Notice, unless a longer retention period is required or permitted by law.

When personal information is no longer required, we will delete it, anonymise it or otherwise handle it in accordance with applicable PRC law and our retention policies.

8. Automated decision-making

We do not use your personal information to make decisions based solely on automated processing that produce legal or similarly significant effects on you, unless we notify you separately and do so in accordance with applicable law.

Where we use automated tools, analytics or profiling in connection with our services, we will do so in accordance with applicable law. Where PRC law applies, you may have the right to request an explanation of automated decision-making and to refuse decisions made solely by automated decision-making where such decisions have a significant impact on your rights and interests.

9. Your PRC privacy rights

Subject to applicable PRC law, you may have the right to:

  • know and decide about the processing of your personal information;
  • restrict or refuse processing;
  • access and copy your personal information;
  • correct or supplement inaccurate or incomplete personal information;
  • request deletion of your personal information;
  • withdraw consent where processing is based on consent;
  • request an explanation of our personal information processing rules; and
  • request transfer of your personal information where applicable legal conditions are met.

To exercise your rights, please contact: DPO@the-independents.com

We may need to verify your identity before responding to your request.

Updated: April 2026

APPENDIX – CROSS-BORDER TRANSFERS OF PERSONAL INFORMATION



Overseas recipient

Country / region

Purpose of transfer

Categories of personal information

Processing method

Retention period

How to exercise rights

Agency Group companies and The Independents Group entities outside Mainland China

UK, EEA, United States, Hong Kong, Singapore, Japan, Korea, Switzerland, UAE and other jurisdictions where group entities operate

Group administration, business relationship management, service delivery, reporting, finance, legal, compliance, IT support, management oversight and internal operations

Identity and contact information, business communications, profile and relationship information, technical and usage information, compliance information, financial and transaction information and other relevant business information

Access, storage, use, organisation, analysis, transmission, hosting, support and reporting

As described in our General Privacy Notice, this Privacy Schedule and our applicable retention policies; generally for as long as necessary for the relevant business, legal, compliance, contractual or operational purpose

DPO@the-independents.com

IT, hosting, cloud, CRM, email, collaboration and system administration providers

UK, EEA, United States, Hong Kong, Singapore and other jurisdictions depending on the provider and system used

Hosting, storage, IT support, system administration, cybersecurity, CRM management, email communications, collaboration tools and business continuity

Identity and contact information, business communications, technical and usage information, profile and relationship information and other information stored in relevant systems

Hosting, storage, access, transmission, support, maintenance, security monitoring and troubleshooting

For the duration of the relevant service and thereafter as required by contract, law or applicable retention policy

DPO@the-independents.com

Clients, brands, event partners, production partners and business partners

Relevant client or partner jurisdictions, which may include the UK, EEA, United States, Hong Kong, Singapore, Japan, Korea, UAE and other event or project locations

Delivering services, managing campaigns, events, productions, collaborations, guestlists, logistics, reporting, client communications and business relationships

Identity and contact information, business communications, profile and relationship information, event or project information, logistics information and other information relevant to the specific service

Access, use, transmission, organisation, analysis, reporting and project administration

For the duration of the relevant project, event, campaign or business relationship and thereafter as required for legal, contractual, audit, reporting or dispute purposes

DPO@the-independents.com

Event, travel, hospitality, logistics and production service providers

Event, travel or production destination countries and provider locations, which may include the UK, EEA, United States, Hong Kong, Singapore, Japan, Korea, UAE and other jurisdictions

Event administration, travel booking, accommodation, transport, hospitality, access control, security, production support and related logistics

Identity and contact information, travel information, passport or identification details where necessary, accommodation details, event attendance, dietary/accessibility information where relevant and other logistics information

Access, use, transmission, booking, coordination, storage and support

For the duration of the relevant booking, event, travel, production or logistics purpose and thereafter only as required for legal, audit, security, insurance or dispute purposes

DPO@the-independents.com

Finance, accounting, payment, banking and professional services providers

UK, EEA, United States, Hong Kong, Singapore, Switzerland and other jurisdictions depending on the provider

Payments, invoicing, accounting, audit, tax, banking, legal, insurance, compliance and professional advisory services

Identity and contact information, financial and transaction information, invoices, payment details, purchase order information, tax/accounting information and relevant business communications

Access, use, storage, transmission, review, reporting, audit and professional advice

For the period required for payment, accounting, tax, audit, legal, regulatory and dispute purposes, in accordance with applicable law and our retention policies

DPO@the-independents.com

Compliance screening, sanctions, anti-bribery, KYC and onboarding providers

UK, EEA, United States and other jurisdictions depending on the provider

Supplier/client screening, sanctions checks, anti-bribery checks, onboarding, compliance, risk management and regulatory recordkeeping

Identity and contact information, employer/company information, role/title, due diligence information, screening results and relevant compliance information

Access, screening, matching, review, storage, reporting and transmission

For as long as necessary for compliance, legal, audit, regulatory, risk management and dispute purposes

DPO@the-independents.com

Professional advisers, regulators, courts, public authorities and law enforcement bodies

Relevant jurisdictions depending on the matter

Legal advice, audit, insurance, regulatory compliance, litigation, investigations, enforcement, reporting and protection of rights

Relevant categories of personal information necessary for the relevant legal, regulatory, audit, insurance, investigation or dispute purpose

Access, use, disclosure, transmission, review, storage and professional analysis

For as long as required or permitted by applicable law, professional obligations, regulatory requirements, litigation hold, audit or dispute purposes

DPO@the-independents.com

Parties involved in corporate transactions, reorganisations, integrations, investments or asset sales

Relevant jurisdictions depending on the transaction

Due diligence, transaction planning, corporate integration, restructuring, investment, merger, acquisition or asset sale

Identity and contact information, business communications, financial and transaction information, contractual information, compliance information and other information relevant to the transaction

Access, review, analysis, disclosure, storage, transmission and integration planning

For the duration of the transaction process and thereafter as required for legal, regulatory, audit, corporate recordkeeping or dispute purposes

DPO@the-independents.com

The Independents Group entities outside Mainland China

UK, EEA, United States, Hong Kong, Singapore, Japan, Korea, Switzerland, UAE and other jurisdictions where group entities operate

Group administration, business relationship management, service delivery, reporting, finance, legal, compliance, IT support, management oversight and internal operations

Identity and contact information, business communications, profile and relationship information, technical and usage information, compliance information, financial and transaction information and other relevant business information

Access, storage, use, organisation, analysis, transmission, hosting, support and reporting

As described in our General Privacy Notice, this Privacy Schedule and our applicable retention policies; generally for as long as necessary for the relevant business, legal, compliance, contractual or operational purpose

DPO@the-independents.com

IT, hosting, cloud, CRM, email, collaboration and system administration providers

UK, EEA, United States, Hong Kong, Singapore and other jurisdictions depending on the provider and system used

Hosting, storage, IT support, system administration, cybersecurity, CRM management, email communications, collaboration tools and business continuity

Identity and contact information, business communications, technical and usage information, profile and relationship information and other information stored in relevant systems

Hosting, storage, access, transmission, support, maintenance, security monitoring and troubleshooting

For the duration of the relevant service and thereafter as required by contract, law or applicable retention policy

DPO@the-independents.com

Clients, brands, event partners, production partners and business partners

Relevant client or partner jurisdictions, which may include the UK, EEA, United States, Hong Kong, Singapore, Japan, Korea, UAE and other event or project locations

Delivering services, managing campaigns, events, productions, collaborations, guestlists, logistics, reporting, client communications and business relationships

Identity and contact information, business communications, profile and relationship information, event or project information, logistics information and other information relevant to the specific service

Access, use, transmission, organisation, analysis, reporting and project administration

For the duration of the relevant project, event, campaign or business relationship and thereafter as required for legal, contractual, audit, reporting or dispute purposes

DPO@the-independents.com or, where appropriate, the relevant client or partner identified to you

Event, travel, hospitality, logistics and production service providers

Event, travel or production destination countries and provider locations, which may include the UK, EEA, United States, Hong Kong, Singapore, Japan, Korea, UAE and other jurisdictions

Event administration, travel booking, accommodation, transport, hospitality, access control, security, production support and related logistics

Identity and contact information, travel information, passport or identification details where necessary, accommodation details, event attendance, dietary/accessibility information where relevant and other logistics information

Access, use, transmission, booking, coordination, storage and support

For the duration of the relevant booking, event, travel, production or logistics purpose and thereafter only as required for legal, audit, security, insurance or dispute purposes

DPO@the-independents.com





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