Point72 Ventures

PRC PRIVACY POLICY (ENGLISH)

PRC PRIVACY POLICY

In this Privacy Policy, “we”, the “Firm”, “us” and “our” means Point72 (Shenzhen) Consulting Co., Ltd., which is registered in the People’s Republic of China (which, for the purpose of this Privacy Policy, excludes the Hong Kong Special Administrative Region, the Macau Special Administrative Region and Taiwan, the “PRC”) with its registered address at 05A-033, Level 5, Loft B, The Town, UpperHills, 5001 Huanggang Road, Futian District, Shenzhen, Guangdong, China.

About this Privacy Policy

Please take the time to read and understand this Privacy Policy.

For the purposes of PRC data protection law (including but not limited to the PRC Personal Information Protection Law, or “PIPL”), we are a personal information processor in respect of your personal information.

This Privacy Policy applies if you are visiting the Point72 family of websites (“P72 Sites”) from the PRC, attending an onsite event or meeting we hosted in the PRC, and in other scenarios where you consent to this Privacy Policy. The Privacy Policy sets out the basis on which any personal information about you will be processed by us.

By using the P72 sites or interacting with us online, you are agreeing to the terms of this Privacy Policy, as posted here. If you do not agree with any terms or practices described in this Privacy Policy, please do not access, use or visit the P72 Sites.

We will only process your personal information as necessary to fulfil the purposes set out in this Privacy Policy as they apply to you.

Personal information that we collect about you

Subject to applicable law, we will collect and process the following personal information about you:

  • Information you provide

We collect information from you when you choose to share it with us. This includes but is not limited to visiting the P72 Sites, submitting information through the P72 Sites, requesting information from us, and contacting us through various electronic means. It is also possible to receive information from web browsers and applications regarding certain of your online activities using cookies, and other similar tracking technologies. The personal information you provide to us as part of the recruiting process shall be processed by us for recruiting and employment purposes.

The information we collect from you may include:

  • Contact information typically set forth on a resume such as your name, address, email address, telephone number;
  • Additional resume information you choose to disclose to us including but not limited to education information, GPAs, volunteer positions and prior employers;
  • Current employer-related information such as your company’s name, address and phone number, as well as your company title;
  • Geolocation data gathered from your computer, mobile device or other electronic device used to access the P72 Sites;
  • Where applicable and with your consent, to deliver advertisements or direct messages through third-party services (including social media) targeted to reach potential candidates on such services who are identified in our internal data bases. This may be done by matching common factors between our data bases and the data bases of third-party services which allow Point72 to provide information to potential candidates whose information and email addresses we possess when such individual expressed an interest in hearing from Point72; and
  • As otherwise set forth at the point of collection.
  • Information collected from other sources

We may obtain personal or other information about you from third parties or other sources including third-party social networks or the “apps” on those pages, and combine this information with the information you provide to us. This information may include your name, username, demographic information, updated address or contain information, interests, and publicly
observed data.

  • Other information we may collect

We, along with third parties or other sources, may collect and store technical and navigation information, such as device type, browser type, Internet protocol address, pages visited, and the average time spent on P72 Sites.

  • Sensitive personal information.

There may be instances in which the personal information that you provide to us or that we collect is considered sensitive personal information under the PIPL (e.g. governmental identifiers and financial information). We only process sensitive personal information if and to the extent permitted or required by applicable law, including after obtaining your separate consent if required. We will seek to protect such information rigorously using the security measures required by the applicable law and, hence, your sensitive personal information should not be processed in a way that will result in negative implications to your personal rights, e.g. harm to your reputation, physical or mental health, personal or property security.

Cookies and similar technologies

We and our third-party service providers may use cookies and similar technologies to support the operations of this website. Cookies are pieces of information that a website places on the hard drive of your computer when you visit the website. Cookies may involve the transmission of information from us to you and from you to us, to another party on our behalf, or to another party in accordance with this Privacy Policy. We may also use cookies to bring together information we collect about you. You can choose to have your computer warn you each time a cookie is being sent, or you can choose to turn off all cookies. If you refuse a cookie when on this website, or if you delete cookies, you may experience some inconvenience in your use of our website.

Uses of your personal information

Your personal information may be stored and processed by us for the following purposes:

  • to maintain the security of the P72 Sites and your personal information
  • to facilitate site navigation and improve website design and functionality;
  • to organise online and offline events;
  • to process your job applications;
  • to comply with any legal or regulatory obligation to which we are subject (including compliance with any request from regulatory authorities or other relevant public authorities);
  • to manage our information technology and to ensure the security and use in accordance with our policies and procedures of our systems (including our email system);
  • to effectively and efficiently administer and manage the operation of our business including establishing, exercising or defending our legal rights for the purposes of legal proceedings;
  • to protect information which is proprietary to us;
  • to maintain compliance with internal policies and procedures, and if appropriate conducting internal investigations.

Disclosure of your information to third parties

We may disclose your personal information to our affiliates within the Point72 group for the purposes of:

  • the management and administration of our business and our affiliates’ business;
  • complying with the functions that each of them may perform relating to regional or global HR operations;
  • assessing compliance with applicable laws, rules and regulations, and internal policies and procedures across our business and our affiliates’ business; and
  • the administration and maintenance of the databases storing personal information relating to you.

We will take steps to ensure that the personal information is accessed only by employees of our affiliates that have a need to do so for the purposes described in this Privacy Policy.

We generally do not share non-public personal information with unaffiliated third parties, except as necessary to perform certain duties such as:

  • third-party service providers in order to perform business or technical support functions to the Point72 group;
  • in response to a judicial process or regulatory inquiry, or as may be otherwise required and permitted by law;
  • as necessary with your valid consent; and
  • as otherwise set forth at the point of collection.

We may share aggregated or anonymous non-personal information with third parties for their marketing or analytics uses.

In case of a potential sale of the company or of its assets, we may communicate your personal information to a potential buyer for the purpose of due diligence operations.

Disclosure of your personal information may also, under certain circumstances, be required by law. Your personal information will also, if necessary and permissible under applicable law, be shared with judicial, tax or regulatory authorities acting in the performance of their duties and the exercise of their powers.

Please see Annex 1 “Data Recipient List” at the end of this Privacy Policy for a list of the organisations to whom we transfer personal information as personal information processors in the PRC (which can independently determine processing purposes and processing methods in personal information processing activities) and their respective contact details and details on what, how and why such organisations process your personal information.

Transfers of personal information outside the PRC

The personal information that we collect from you may be transferred to, and stored at, a destination outside the PRC, in particular, the United States. It may also be processed by individuals operating outside of the PRC who work for our affiliates in the United States or elsewhere or for one of our suppliers. Please see Annex 1 “Data Recipient List” at the end of this Privacy Policy for a list of recipients outside of the PRC, and their respective contact details and details on what, how and why such organisations process your personal information and, where required, how you can exercise your data privacy rights in respect of those organisations.

Where we transfer your personal information outside the PRC, if required by applicable law, we will:

  • conduct a security assessment;
  • undergo a personal information protection certification; or
  • sign standard contracts for cross-border transfer of personal information

and take necessary measures to ensure that it is protected in a manner that is consistent with how your personal information will be protected by us in the PRC.

In other circumstances the law may permit us to otherwise transfer your personal information outside the PRC. In all cases, however, we will ensure that any transfer of your personal information is compliant with data protection law.

You can obtain more details about the protection given to your personal information when it is transferred outside the PRC (including a copy of the standard data protection clauses which we have entered into with certain recipients of your personal information) by contacting us in accordance with the “Contacting us” section below.

Retention of personal information

How long we hold your personal information for will vary. The relevant retention period will be determined by various criteria including:

  • the nature and duration of your interaction with us;
  • legal obligations which require the Firm to keep your personal information as archives after the expiration of your interaction with us; and
  • the establishment, exercise or defence of the Firm’s rights, which will require us to store your personal information as archives.

Your rights

You have a number of legal rights in relation to your personal information held by us. You can ask us to:

  • provide you with information regarding the processing of your personal information, and access the personal information which we hold about you;
  • in certain circumstances, provide you with a copy of your personal information in a structured, commonly used and machine-readable format and/or request that we transmit those data to a third party;
  • correct and supplement your personal information if it is inaccurate or incomplete;
  • erase your personal information;
  • restrict our processing of your personal information. In certain circumstances you can also object to our other processing of your personal information; and
  • explain the rules for Personal Information processing.

These rights will be limited in some situations; for example, where we are required to process your personal data by PRC law or where we are legally entitled to refuse your request.

You can also lodge a complaint with the data protection regulator (details of which are provided below) if you think that any of your rights have been infringed by us. To exercise your rights, please contact us using the details set out below.

Protecting children’s privacy online

P72 Sites are not directed to individuals under the age of fourteen (14). We do not knowingly collect personal information from individuals who are under fourteen (14).

Third-party websites

Point72 may establish links between the P72 Sites and one or more websites operated by third parties. Point72 has no control over websites owned or run by unaffiliated third parties, and your access to and use of such linked websites is governed by the user agreement and privacy policies of such websites.

Contacting us

If you have questions on this policy or would like to access, correct, update or delete your personal information, please contact Point72 at dataprivacy@Point72.com or the Data Privacy Hotline at +1 203-890-2868.

Changes to this Privacy Policy

This Privacy Policy takes effect on 24 July 2023. If we change it to the extent permitted by application law, to keep you fully aware of our processing of your personal information and related matters, we will post the new version on the P72 Sites.

Language of this Privacy Policy

This Privacy Policy is written in both English and Chinese. In the event of any inconsistency between the English language version and the Chinese language version, the English language version shall
prevail.

Annex 1: Data Recipient List

  1. Organisations in the PRC

    Name: WeWork Commercial Information Consulting (Shenzen) CO., Ltd.

    Contact Details:

    Email address: gccompliance@wework.cn

    Postal address:

    Unit 101, 9th Floor (8th Floor), Building 3

    N0. 2, Lane 838, South Huang Pi Road

    Huangpu District, Shanghai, China

    Processing purpose, method, categories of personal information shared: Please find more details at https://www.wework.cn/en-US/guide/privacy

  2. Organisations outside of the PRC

Name: Point72, L.P. and its non-PRC affiliates

Contact Details:

Email address: dataprivacy@Point72.com

Privacy hotline: +1 203-890-2868

Processing purpose, method, categories of personal information shared: Please find more details at Global Privacy Policy – Point72