PRIVACY STATEMENT
Our Privacy Commitments
MetalFirst and Xiamen Nickel Limited (together "we" or “us”) respect the privacy of every person who visits,
registers with or subscribes to our websites and online publications ("you"), and are committed to ensuring a
safe online experience.
This Privacy Statement outlines the information we may collect about you in relation to your use of our websites
and related publications and services and how we may use that personal data. It also outlines the methods by
which we and our service providers may (subject to necessary consents) monitor your online behaviour in order to
deliver customised advertisements and marketing materials and other tailored services.
This Privacy Statement applies to all websites operated by us (as indicated on the relevant website) (" Sites
"). For the purpose of this Privacy Statement, "company" shall mean Xiamen Nickel Limited and any of its
subsidiary companies, including, without limitation, MetalFirst. Please note that the Sites may contain links to
external sites and may contain advertisements for, and/or the opportunity for you to purchase products or
services from third parties. This Privacy Statement does not cover the activities of such third parties, and you
should consult those third-party sites` privacy policies for information on how your data is used by them.
By accessing and using the Sites you are agreeing to the terms of this Privacy Statement.
Information about us
Our principal business activities are:
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Business-to-Business Financial Publishing. We provide a range of products and services focused on
international finance, metals, commodities, telecoms and emerging markets including magazines,
newsletters, electronic information and data
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Organisers of Seminars, Conferences, Training Courses and Exhibitions for the financial markets industry
Xiamen Nickel Limited (MetalFirst)
P.R. China
Name of the Data Controller
The Data Controllers are Xiamen Nickel Limited and MetalFirst.
Collection of Personal Data
Our primary goal in collecting personal data from you is to give you an enjoyable customised experience whilst
allowing us to provide services and features that most likely meet your needs.
We collect certain personal data from you, which you give to us when using our Sites and/or registering or
subscribing for our products and services. However, we also give you the option to access our Sites` home pages
without subscribing or registering or disclosing your personal data.
We also collect certain personal data from other group companies to whom you have given information through
their websites (including, by way of example, Xiamen Nickel Limited and MetalFirst, in accordance with the
purposes listed below).
Please note that we do not intend to collect any personal data from children under thirteen years of age and no
child under thirteen should submit any personal data to any of the Sites. Should we discover that any such
personal data has been delivered to any of the Sites, we will remove that information as soon as possible.
Purpose of Data Collected
We set out in the table below all the ways we plan to use your personal information and the legal basis we rely
on to do so. We also explain what our legitimate interests are where appropriate:
Jiguang SDK
Lawful basis for processing including our legitimate interests:
Provide information push service for APP users
Processing necessary to achieve purpose:
Type of personal information collected: Device parameters and system information (device type, device model,
system version, and related hardware information) : Used to identify the user's device type, device model, and
system version to ensure accurate delivery of the message. Device identifiers (IMEI, IDFA, Android ID, GID, MAC,
OAID, VAID, AAID, IMSI, MEID, UAID, SN, ICCID, SIM information) : used to identify unique users to ensure
accurate delivery and accurate statistics of push information. Network information (IP address, WiFi
information, base station information, DNS address, DHCP address, SSID, BSSID) and location information
(latitude and longitude) : used to optimize the network connection request between SDK and Aurora server, ensure
the stability and continuity of service, and realize regional push function; APP list information (APP crash
information, notification switch status, APP list and active status, app page information, app function event
information) : When a device has multiple APP push links active at the same time, we adopt the link merging
technology to randomly merge into one link, so as to save power and traffic for users. Data processing methods:
through to identification, encrypted transmission and other website link: https://www.jiguang.cn/push privacy
policy links: https://www.jiguang.cn/license/privacy
To on-board you as a new customer
Lawful basis for processing including our legitimate interests:
To fulfil our contract with you
To fulfil our legal obligations to prevent financial crime
Processing necessary to achieve purpose:
Collection
Storage
Organisation
Transfer
Disclosure
To monitor your use of the Subscription Service and your license(s) on an on-going basis
Lawful basis for processing including our legitimate interests:
Necessary for our legitimate interests – for billing purposes
To fulfil our contract with you
Processing necessary to achieve purpose:
Storage
Organisation
Transfer
Retrieval
Consultation
To contact you about other services or products via promotional materials or other media
Lawful basis for processing including our legitimate interests:
Necessary for our legitimate interests – to develop our products and services and grow our
business
Processing necessary to achieve purpose:
Collection
Storage
Organisation
Retrieval
Consultation
To notify you about changes to our Sales Order, Terms of Business or Privacy Statement, and to
communicate with you in response to any of your queries or requests
Lawful basis for processing including our legitimate interests:
To fulfil our contract with you
To fulfil our regulatory obligations
Processing necessary to achieve purpose:
Collection
Storage
Organisation
Retrieval
Consultation
（g）其他法律法规等规定，司法机关或行政机关要求的情形。
Types of Personal Data Held and its Use
1. Customer Services and Administration
At some Sites, Xiamen Nickel Limited collects personal data such as your name, job title, work and/or home
address, and telephone number and email address in order to register you for access to certain content and
subscriptions. This information may be supplemented with demographic information from your use of our Sites such
as your postal area, age, gender, purchasing preferences and interests.
At other Sites, Xiamen Nickel Limited may only collect broad demographic information for aggregate use.
2. Monitoring use of our Sites
Where, as part of our Site services, we enable you to post information or materials on our Site, we may access
and monitor any information which you upload or input, including in any password-protected sections. Subject to
any necessary consents, we also monitor and/or record the different Sites you visit and actions taken on those
Sites, e.g. content viewed or searched for. If you are a registered user (e.g. a subscriber or taking a trial),
when you log on, this places a cookie on your machine. This enables your access to content and services that are
not publicly available. Once you are logged on, the functional actions you take - for example, viewing an
article – may be recorded.
3. Cookies and similar technologies
All our Sites use cookies and similar technical tools to collect information about your access to the Site and
the services we provide.
Cookies are pieces of information which include a unique reference code that a website transfers to your device
to store and sometimes track information about you. A number of cookies we use last only for the duration of
your web session and expire when you close your browser. Other cookies are used to remember you when you return
to the Site and will last for longer. Cookies cannot be used to run programs or deliver viruses to your
computer. They are uniquely assigned to you and can only be read by a Web server in the domain that issued the
cookie.
We may use cookies to:
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remember that you have used the Site before; this means we can identify the number of unique visitors we
receive to different parts of the Site. This allows us to make sure we have enough capacity for the
number of users that we get and make sure that the Site runs fast enough;
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remember your login session so you can move from one page to another within the Site; or store your
preferences or your user name and password so that you do not need to input these every time you visit
the Site;
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customise elements of the layout and/or content of the pages of Site for you;
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record activity on our Sites so that we understand how you use our Sites enabling us to better tailor
our content, services and marketing to your needs;
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collect statistical information about how you use the Site so that we can improve the Site;
and
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gather information about the pages on the Site that you visit, and also other information about other
websites that you visit, so as to place you in a “market segment”. This information is only collected by
reference to the IP address that you are using, but does include information about the county and city
you are in, together with the name of your internet service provider. This information is then used to
place interest-based advertisements on the Site which it is believed will be relevant to your market
segment. Some of the cookies used by our Sites are set by us, and some are set by third parties who are
delivering services (such as interest based advertising directed at your market segment) on our behalf.
Most web browsers automatically accept cookies but, if you prefer, you can change your browser to prevent that
or to notify you each time a cookie is set. You can also learn more about cookies in general by visiting
www.allaboutcookies.org which includes additional useful information on cookies and how to block cookies using
different types of browser. Please note however, that by blocking, deleting or turning off cookies used on the
Site you may not be able to take full advantage of the Site.
Email tracking
So that we can better understand our users` needs, we track responses to our emails - for example, to see
which links are the most popular in newsletters, and to log and follow up responses to our marketing messages.
To do this, we use pixel GIFs, also known as "pixel tags" - these are small image files that are placed within
the body of our email messages. They enable us to tell if a message has been opened and to track click-throughs
on links within the message.
Consents and opt-outs
You can give your consent to or opt out of particular uses of your data as indicated above by:
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Indicating at the point on the relevant Site where personal data is collected;
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Informing us by email, post or phone; or
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Updating your preferences on the applicable Site;
Marketing Communication
We, our group companies or other third-party service providers may send you marketing communications if you have
agreed to receive such communications and in each case you have not opted-out of receiving such communications,
or you have asked for information about us and requested we keep you updated about our business and services. We
believe as a commercial enterprise we do have a legitimate interest in contacting you about our products or
services by utilizing your personal data, and we will only do so if we decide it would be of interest or
beneficial for you.
Disclosures
Information collected at one Site may be shared between Xiamen Nickel Limited and MetalFirst and other group
companies for the purposes listed above (“purposes of data collected”).
We may also disclose your personal data to other third parties, including, without limitation, professional
advisers, or governmental or State institutions or regulatory authorities, where necessary in order to exercise
or defend legal rights or where required by law.
Public forums, message boards and blogs
Some of our Sites make message boards, blogs or other facilities for user generated content available and users
can participate in these facilities. Any information that is disclosed in these areas becomes public information
and you should always be careful when deciding to disclose your personal information.
Confidentiality and Security of Your Personal Data
We are committed to keeping the data you provide us secure and will take reasonable precautions to protect your
personal data from loss, misuse or alteration.
The transmission of information via the internet is not completely secure. Although we will do our best to
protect your personal data, we cannot guarantee the security of your data transmitted to our Site; any
transmission is at your own risk. Once we have received your information, we will use strict procedures and
security features described above to try to prevent unauthorised access.
We have implemented information security policies, rules and technical measures to protect the personal data
that we have under our control from:
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unauthorised access
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improper use or disclosure
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unauthorised modification
All our employees, contractors and data processors (i.e. those who process your personal data on our behalf, for
the purposes listed above), who have access to, and are associated with the processing of your personal data,
are obliged to keep the information confidential and not use it for any other purpose than to carry out the
services they are performing for us.
We also give you the option of using a secure transmission method to send us personal data identifiers, such as
credit card details and bank account number.
Data Retention
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected
it for, including in order to meet any legal, accounting, or regulatory requirements.
Your Rights and Your Personal Data
If you wish to know whether we are keeping personal data about you, or if you have an enquiry about our privacy
policy or your personal data held by us, in relation to any of the Sites, you can contact the Data Protection
Officer via:
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Postal mail to this address:
Xiamen Nickel Limited
202 Room , 38 Building, Wu Yuan Nan Li,
Huli, Xiamen 361000
P.R. China
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Telephone: + 86-592-8706787
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Email: info@metalfirst.com
In accordance with the relevant jurisdictional and EU data protection laws, subjects have the right in relation
to personal data that includes the right to request access to your personal data, to correct it, have it erased,
restrict it from being used, object to it being processed, to the portability of data and to withdraw consent at
any time. You can request such rights by mailing, dialling or emailing to the above address, telephone number or
email address respectively. We may also need to seek further information from you to confirm your identity
before we release any personal information.
Any other purposes for which Xiamen Nickel Limited or MetalFirst wishes to use your personal data will be
notified to you and your personal data will not be used for any other such purpose other than as informed in
this Privacy Statement, either by notifying you by an update of this Privacy Statement or by obtaining your
prior consent.
We reserve the right to transfer, sell or assign any of the information described in this policy to third
parties as a result of a sale, merger, consolidation, change of control, transfer of assets or reorganisation of
our business.
Changes to this Privacy Statement
We will occasionally update this Privacy Statement to reflect new legislation or industry practice, group
company changes and customer feedback. We encourage you to review this Privacy Statement periodically to be
informed of how we are protecting your personal data.
This Privacy Statement was last updated in June 2018.
This Privacy Statement has been translated into Chinese. If there is any inconsistency or ambiguity between the
English version and the Chinese version, the English version shall prevail.