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Privacy Policy        Shanghai Ganglian Privacy Policy.pdf

PRIVACY STATEMENT

Our Privacy Commitments

Shanghai Ganglian E-commerce Co., Ltd and Mysteel (together "we") 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 ("personal data") 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 also
tells you how you can verify the accuracy of your personal data and how you can request that we delete or update it.

This Privacy Statement applies to all websites operated by us (as indicated on the relevant
website) ("Sites"). For the purpose of this Privacy Statement "group company" shall mean
Shanghai Ganglian and any of its subsidiary companies, including, without limitation, Mysteel.
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:

. 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
. Organisers of Seminars, Conferences, Training Courses and Exhibitions for the financial markets industry

Shanghai Ganglian E-Commerce Holdings Co., Ltd (Mysteel)

68 Yuanfeng Road

Baoshan District

Shanghai

200444

P.R. China

Name of the Data Controller

The Data Controllers are Shanghai Ganglian and Mysteel.

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, Shanghai Ganglian E-

commerce Co., Ltd and Mysteel, 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.

Types of Personal Data Held and its Use

1. Customer Services and Administration

At some Sites, Shanghai Ganglian 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, Shanghai Ganglian may only collect broad demographic information for aggregate use.

This information is used to administer and deliver to you the products and/or services you have
requested, to operate our Sites efficiently and improve our service to you, and to retain records of
our business transactions and communications. By using the Sites and submitting personal
information through the registrati{ԌE{Ԍg that we may collect, hold, process
and use your information (including personal information) for the purpose of providing you with
the Site services and developing our business, which shall include (without limitation) the
purposes described below in paragraphs 2 and 3.

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 actions you take - for example, viewing an article - will be
recorded (subject to any necessary consents). We may use technology or a service provider to
do this for us. This information may be used for one or more of the following purposes:

o to fulfil our obligations to you;
o to improve the efficiency, quality and design of our Sites and services;
o to see which articles, features and services are most read and used
o to track compliance with our terms and conditions of use, e.g. to ensure that you are
acting within the scope of your user licence;
o for marketing purposes (subject to your rights to opt-in and opt-out of receiving certain
marketing communications) - see paragraph 3 below;
o for advertising purposes, although the information used for these purposes does not
identify you personally. Please see paragraph 5 below for more details;
o to protect or comply with our legal rights and obligations; and
o to enable our journalists to contact and interact with you online in connection with any
content you may post to our Sites.

Please see paragraph 5 below for more information on cookies and similar technologies and a
link to a page where you can turn them on or off.

3. Marketing:

Some of your personal data collected under paragraphs 1 and 2 above may be used by us
and/or our other group companies and third party service providers to contact you by email, fax,
telephone and/or post for sending information or promotional material on our products and/or
services and/or those of our other group companies.
We give you the opportunity to opt-out of receiving marketing communications and will in certain
circumstances need to obtain your consent before sending such communications to you. Further
detail can be found on the applicable Site and in each marketing communication sent by us, our
group companies or service providers. See also "Consents and opt-outs" section below.

4. Trading in Personal Data:

Some of your personal data may be collected and processed with the intention of selling it to
other organisations, but this will not be done unless you have given your consent (separately to
this privacy statement).

5. 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:

o 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;
o remember your login session so you can move from one page to another within the Site;
o store your preferences or your user name and password so that you do not need to input
these every time you visit the Site;
o customise elements of the layout and/or content of the pages of Site for you;
o 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;
o collect statistical information about how you use the Site so that we can improve the Site; and
o 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.
Any other purposes for which Shanghai Ganglian wishes to use your personal data will be
notified to you and your personal data will not be used for any such purpose without obtaining
your prior consent.

Consents and opt-outs

You can give your consent to or opt out of particular uses of your data as indicated above by:

. Indicating at the point on the relevant Site where personal data is collected;
. Informing us by email, post or phone; or
. Updating your preferences on the applicable Site;

For turning cookies and similar technologies on and off, see the information in paragraph 5 above.

Disclosures

Information collected at one Site may be shared between Shanghai Ganglian E-commerce Co.,
Ltd and Mysteel and other group companies for the purposes listed above.

Your personal data may also be sold to other companies in the form of lists and directories, but
only after permission from you in accordance with the provisions above.

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.

We may 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.

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:

. unauthorised access
. improper use or disclosure
. unauthorised modification
. unlawful destruction or accidental loss

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.

How to Access, Update and Erase your Personal Information

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:

. Postal mail to this address: Data Protection Officer, Shanghai Ganglian E-commerce Co.,
Ltd, 68 Yuanfeng Road, Baoshan District, Shanghai,200444, P.R. China
. Telephone: + 86-21-2609-3000

Upon request, we will provide you with a readable copy of the personal data which we keep
about you. We may require proof of your identity and may charge a small fee (not exceeding the
statutory maximum fee that can be charged) to cover administration and postage.

Shanghai Ganglian allows you to challenge the data that we hold about you and, where
appropriate in accordance with applicable laws, you may have your personal information:

. erased
. rectified or amended
. completed

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 May 2017.

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Shanghai Ganglian E-Commerce Co., Ltd.
Business Address: 68 Yuan Feng Road, Bao Shan District, Shanghai, 200444, P.R. China

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