Customers Privacy Notice

Last Updated: September 26, 2023

Air Liquide (China) Holding Co., Ltd. and its subsidiaries and affiliates (“Air Liquide” or “We”) are committed to being responsible for processing your personal information.

Before you use or submit any information, please carefully review this Privacy Notice (this “Notice”). We will continue to evaluate this Notice to reflect our personal information processing activities, and we may make changes to this Notice accordingly. Any changes will be made on this page, and you should check this page periodically for updates. If we make material changes to this Notice, we will provide you with notice when required by law.

This Notice contains the following sections:

1. Application and definition 

2. How we collect and use your personal information 

3. How we share your personal information 

4. Legal bases for processing your personal information 

5. How we store your personal information 

6. How we protect your personal information 

7. Your choices and rights 

8. How we protect children’s PI 

9. How do we transfer your personal information globally 

10. The links to other websites and services 

11. Updates to this policy 

12. Contact us 

This Notice governs and describes our practices (as a personal information processor under China’s data and privacy law) in connection with personal information that we collect in the course of our interactions with business customers or potential customers in Mainland China, including providing service, direct contacts, through myGAS platform, Gasfun Taobao e-store, 1688 platform or WeChat mini-programmes, etc. 

Definitions of “personal information”, “sensitive personal information”, and “processing” in this policy are set out as follows and are consistent with the definitions in the relevant laws.

• Personal information: refers to various types of information recorded in electronic or other ways that is related to an identified or identifiable natural person, including but not limited to name, address, mobile phone number, and ID number, etc. but excluding anonymized information.
• Personal information processor: refers to an organization or individual that independently decides on the processing purposes and processing methods during PI processing activities. 
• Sensitive personal information: refers to personal information that, if leaked or used illegally, may easily lead to an infringement upon the human dignity of a natural person or endangerment of the safety of his/her body or property, including information on biometric identification, religious beliefs, specific identity, health care, financial accounts, and personal whereabouts, and personal information of minors under the age of fourteen. Sensitive personal information is in bold, italic and underlined to draw your attention.
• Processing: includes personal information collection, storage, use, processing, transmission, provision, disclosure and deletion, etc. 

We will only collect and process your personal information for the following purposes described in this policy in accordance with the principles of lawfulness, legitimacy, necessity and good faith and in compliance with applicable laws and regulations.

2.1 When you are directly contacted by employees of Air Liquide, for the purposes of business liaison and establishing business partnership (such as a contractual relationship) with your company, we may collect and use your name, e-mail address, phone number, WeChat ID (if applicable), job title, and the information of the business presence by which you are employed. 

2.2 When Air Liquide China processes your company’s orders and provides your company with related products and services, in order to generate, manage and deliver orders, create a profile and open an account for you or your company in our system, send contracts, invoices and other documents and deliver goods, we will collect and use your or your company’s name, e-mail, phone number, position, and delivery address. 

2.3 If you work for a hospital customer, when you purchase our medical oxygen products, we need to create a profile for your company. We will collect and use the copy of your ID card in order to meet the drug management requirements of Good Selling Practice (GSP). 

2.4 When you participate in customer surveys initiated by Air Liquide China, for the purposes of processing feedback and analysing the degree of customer satisfaction, we will collect and use name, e-mail, phone number/WeChat ID and the content of the customer survey as provided by you.

2.5 When you make an appointment to visit our sites, due to our security management needs, we will collect your name, phone number, job position, your company information, email address and ID card number.

2.6 When you purchase our products or experience our services through the 1688 online store, we may collect your name, phone number, and address from such an e-commerce platform.

2.7 If you or your colleagues get injured because of the products or services we provide, you may need to submit the pathological information so that we can better recognize the incidents and provide assistance to you or your colleagues. The pathological information includes medical records and examination reports of the injured, photos of the injured parts, CT and X-ray photo. You understand and acknowledge that if you provide us with your colleague’s personal information, you need to ensure that the colleague has been informed of the processing of the personal information and has given his or her separate consent.

2.8 When you register as a user of our myGAS platform, for the purpose of opening an account for you, granting access right to view delivery record, request invoices, and order online, we will collect and use your name, email address and phone number.

2.9 When you fill out the feedback form on our myGAS platform, for the purpose of handling your feedback as quickly as possible, we will collect and use your name, email and phone number.

In order to achieve the purposes above, we may entrust third-party service providers (such as suppliers, IT service providers, logistic service providers and legal service providers) to assist us and we will send your personal information to them. For companies, organizations and individuals who we entrust to process your personal information, we ask them to handle your personal information in accordance with our instructions, this Notice and applicable laws.

For the medical oxygen products, we may be subject to unannounced inspections by the government department responsible for pharmaceutical supervision in accordance with the Good Manufacturing Practice (GMP) and Good Supply Practice (GSP) requirements. If you or the company you represent purchase medical oxygen products from us,  your identification information (including ID card information)  might be subject to random checks by such government authorities.

In most circumstances, we rely upon your consent to process your personal information. While under the relevant laws, we do not require your consent to process (including but not limited to, the collection, storage, use, processing, transmission, provision, disclosure, and deletion.) your personal information when:

1. the processing is necessary to fulfill statutory functions or statutory obligations; 
2. the processing is necessary to respond to public health emergencies or protect the life, health or property safety of natural persons under emergency circumstances; 
3. personal information is processed within a reasonable scope to conduct news reporting, public opinion-based supervision, or other activities in the public interest;
4. the personal information that has been disclosed by the individuals themselves or other personal information that has been legally disclosed is processed within a reasonable scope in accordance with this Law; or
5. under any other circumstance as provided by any law or administrative regulation. 

We only retain your personal information within the minimum period which is necessary for the fulfillment of the purposes stated in this Notice. Meanwhile, we will also store your personal information with adherence to the mandatory provisions about the retention period rising from applicable laws and regulations.

We have implemented industry-accepted administrative, technical, and physical security measures to protect the personal information you provide and to prevent the data from being accessed, disclosed publicly, used, modified, damaged or lost without authorization. We will take all reasonable and practicable measures to protect your personal information.

However, we cannot and do not guarantee that these measures will provide absolute security. Where a personal information security breach occurs unfortunately, we will inform you as required by the laws and regulations via mail, letter, telephone, push notification or other available means. Where it is difficult to inform the subjects of the personal information one by one, we may publish an announcement on our Services. Where required by law, we will also report the treatment result of the personal information breach. 

According to applicable law, you may have: 

1. the right to know and the right to decide on the processing of your personal information; 
2. the right to restrict or refuse the processing of your personal information by others; 
3. the right to consult and duplicate your personal information; 
4. the right to request personal information processors to correct or supplement your personal information where you discover the information is incorrect or incomplete; 
5. the right to withdraw your consent to the processing of personal information based on your consent (but please note that your withdrawal of consent does not affect the validity of the processing of personal information that has been carried out based on your consent before the withdrawal); 
6. the right to request the transfer of personal information to your designated personal information processors; 
7. the right to delete your personal information under specific circumstances. 

If you hope to exercise your rights above, please contact us via the contact information provided in this Notice. To protect the security of your personal information, we need to verify your identity in order to respond to your rights request(s), and we may not be able to respond to the request(s) for rights related to personal information that are not from you or authorized by you (for example, requests to consult personal information of someone else). 

Additionally, the rights above are subject to limitations and exceptions under applicable law. We will respond to and comply with your request(s) consistent with applicable law as soon as reasonably practicable. If you have unresolved concerns, you also have the right to complain to relevant supervisory authorities or where applicable, file a lawsuit with the court in accordance with applicable law.

Our services are not for children under the age of 14 and we do not knowingly collect personal information from children under the age of 14. If you are under 14 years of age, please do not use or access the service we provide at any time or in any method. We do not knowingly collect personal information from children for any purpose. If you believe that we have personal information about a child without the consent of the parent or guardian, or if you are the parent or guardian of the child and wish to withdraw consent, please contact us using the contact information provided in this policy and we will delete the relevant personal information.

Since Air Liquide is a multinational corporation, as part of our international operations, our business entities and departments may transmit information with affiliate companies who conduct the personal information processing activities under our instructions and on our behalf:

For the purposes stated in the Privacy Notice, we may transfer your personal information to our affiliates and third-party companies located outside of China as noted above. Where personal information is transferred to another jurisdiction outside mainland China, your personal information will be secured by appropriate safeguards as set forth under applicable law, including without limitation, where applicable by the use of the standard contract to be published by the supervisory authority for the transfer of Information between mainland China and other jurisdictions. To the extent required under applicable law, we will obtain separate consent from you before the transfer of your personal information.

The online services (e.g., myGAS) we provide may access or link to third-party websites, applications and other services. Please note that we are not responsible for the privacy practices of such other websites and services. We encourage you to be aware of and read the privacy policy of each website you visit that collects information about you when you leave our services.

We reserve the right to update this Notice at any time to reflect changes in the law, our data collection or practices, the features of our services, or advances in technology. We will provide you with a new privacy notice when required by law. We may also notify you in other ways from time to time about the processing of your personal information.

If you have questions about this privacy notice or wish to contact us for any reason in relation to our personal information processing, please contact us at cn-privacy@airliquide.com.