Privacy policy

Welcome to (“Website”). This website (including all access via a web browser and all related applications) is provided, owned and operated by C&A Advisors Enterprises Management Consulting (Shanghai) Co, Ltd (“ORCOM C&A”). ORCOM C&A is committed to protecting your privacy.

The privacy policy is written in English and may be translated into other languages. In the event of any inconsistency between the English version and other translated versions, the English version shall prevail. ORCOM C&A reserves the right to modify the privacy policy as needed, particularly when it needs to be updated due to changes in its data processing practices or activities.

Please read and understand the Privacy Policy carefully before using ORCOM C&A’s services or this website, especially the terms in bold. Your choice to use or continue to use ORCOM C&A’s services and to use this website means that you have fully understood the contents of the Privacy Policy and agree that ORCOM C&A may process personal information in accordance with the purposes and means of processing set out below, and with the extent of disclosure of such data. For the avoidance of doubt, personal information (“personal information”) refers to any information (excluding anonymized information) recorded electronically or by any other means, concerning any identified or identifiable natural person.


Your personal information is collected and may be processed following your visit to this website, using the following types of data:

(1) Navigation data

The information systems and software procedures implemented to operate this website may, in the normal course of operations, collect certain personal information whose transmission is implicit in the use of Internet communication protocols.

This is information that is not collected in order to be associated with identified subjects, but which, due to its intrinsic nature, may, through processing and in conjunction with data held by third parties, enable your identification.

This category of data includes the IP addresses or domain names of your computers connecting to this website, the URI (Uniform Resource Identifier) identifier for the resource request, the request time, the request to submit the procedure to the server, the size of the response file obtained, the code describing the server’s service status (success, error, etc.) and other parameters relating to the operating system and your environment settings.

This data is only used to collect anonymous statistical information on visits to this website and to monitor its proper operation, and is deleted immediately after processing. The data may be used to determine liability in the event of an attack or hacking of the site: with the exception of this risk, the data is not normally kept for more than seven (7) days.

(2) Data voluntarily provided by you

The transmission at your discretion, explicit and voluntary of electronic mail to the addresses of this website will entail the collection of your address in order to respond to requests, possibly in addition to other personal information contained in the sending. At your request, certain summary lines will be progressively visualized on this website.

(3) In addition to what has been mentioned in relation to browsing data, you have the choice to provide personal information such as name and e-mail address on designated forms, in order to receive certain information or other types of communication. This type of personal information will only be used to respond to your requests in accordance with the laws applicable in the People’s Republic of China (”PRC”).

You are aware of and agree that ORCOM C&A may process your personal information as described above in accordance with the Privacy Policy and in compliance with applicable laws. The processing of data related to the services of this Site is managed solely by ORCOM C&A’s technical personnel who are in charge of processing or maintenance.


This website does not intentionally collect any personal information from you. No cookies or tracking systems of any kind will be used in the transmission of your personal information.

The use of session cookies (“session cookies” which are not permanently stored on your computer and are deleted once the browser is closed) is strictly limited to identifying session information (numbers randomly generated by the server), which is necessary to operate this website and improve your user experience. Session cookies avoid the use of other means of information technology, which can potentially infringe on your privacy, and do not allow the collection of your personally identifiable information.

In any case, if you choose to refuse the downloading of any type of cookies from this or other websites, you can increase the level of privacy protection by modifying your browser settings.

ORCOM C&A informs you that you may request the deletion of information collected through cookies at any time.


ORCOM C&A may use your Personal Information in the following situations:

  • ORCOM C&A will use your personal information, in accordance with the Privacy Policy, to provide these services;
  • to ensure the stability and security of the services, ORCOM C&A will use your personal information for the purposes of identity authentication, security measures, fraud monitoring, prevention or prohibition of illegal activities, risk reduction, archiving and backup;
  • ORCOM C&A may use your Personal Information to perform data analysis to help ORCOM C&A improve its services, thereby providing you with services that may better meet your needs. ORCOM C&A may share your personal information with government agencies, legal authorities or third parties in accordance with applicable laws, regulations or regulatory requirements in the PRC; and
  • ORCOM C&A will compile statistics on the use of the services and may share this statistical data (which excludes your personal information) with the public or third parties to show general trends in the use of the services.

ORCOM C&A will use your Personal Information :

  • within the framework of your prior authorization or consent.
  • if ORCOM C&A uses your personal information without your prior consent, additional consent may be required from you.
  • in accordance with the Privacy Policy and applicable laws in the PRC.

You acknowledge and agree that ORCOM C&A may use your Personal Information for the purposes set forth above.


Your Personal Information will be processed automatically, strictly limited to the time required for its intended use.

Appropriate security measures are in place to prevent loss, illegal use and inappropriate or unauthorized access to data. ORCOM C&A has adopted all the minimum security measures required by law.

ORCOM C&A, in accordance with key international standards and applicable laws in the PRC, has also adopted additional security measures to protect the personal information collected and processed, and to minimize risks to the availability and confidentiality of the data collected.

If ORCOM C&A’s physical, technical or backup facilities are damaged, resulting in unauthorized access, public disclosure or destruction of your personal information, ORCOM C&A will notify you immediately and take steps to minimize the corresponding risks.


Your Personal Information may be transferred or communicated, strictly for the purposes intended and necessary, to other ORCOM C&A offices, for service operations, such as the management of information systems, or for processing carried out by these offices for the same purposes.

The personal information you provide in connection with an information request (brochures and information, etc.) is only used to carry out these services or information offers and is only disclosed to third parties if this is necessary to carry out the services (companies providing envelopes, labelling and dispatch).

Except as noted above, personal information shall not be disclosed or transferred to third parties unless:

  • your written consent to share data with third parties has been communicated to ORCOM C&A;
  • there is a need to share information with third parties in order to provide the requested service;

there is a need to comply with requests from judicial or public security authorities

You are aware of and agree that ORCOM C&A may share your personal information with the aforementioned third parties for the purposes described in the Privacy Policy and in accordance with its provisions.


In the following circumstances, you agree that ORCOM C&A may collect and use your personal information without your consent:

  • when it is necessary for the conclusion or performance of a contract to which you are a party, or when it is necessary for the management of human resources within the framework of a legally established employment policy or a legally concluded collective contract;
  • when necessary to fulfill a legal responsibility or obligation;
  • when necessary to respond to a public health emergency or to protect the life, health or property of the individual in the event of an emergency;
  • when personal information is processed, to a reasonable extent, for the purposes of news reporting, public opinion monitoring or any other activity in the public interest;
  • where personal information, which has already been disclosed by the individual or otherwise lawfully disclosed, is processed to a reasonable extent and in accordance with applicable PRC laws; and
  • any other circumstances as provided for in the privacy policy, law or administrative regulations applicable in the PRC


In principle, ORCOM C&A will store your personal information in the PRC. In certain circumstances, where permitted by applicable law and subject to business needs, your personal information may be transferred and processed outside the PRC or accessed outside the PRC. If ORCOM C&A transfers your personal information outside the PRC, ORCOM C&A will take steps to protect and safeguard your personal information to ensure that it is treated securely and in accordance with the Privacy Policy and applicable PRC laws. Jurisdictions outside the PRC may have different data protection laws or no applicable data protection laws at all. In such circumstances, ORCOM C&A will protect your personal information to the same extent as the PRC. ORCOM C&A will always guarantee the security of information during management, technical processing and other processes, in order to prevent your personal information from being damaged in various foreseeable accidents.

To better protect your personal information, ORCOM C&A :

  • will ask for and obtain your prior consent before transferring your personal information outside the PRC;
  • will inform you of the specific elements and contents concerning the personal information to be transferred outside the PRC, such as the name of the foreign recipient, his contact details, the purpose of the transfer outside the PRC, the processing method, the type of personal information to be transferred outside the PRC, etc;
  • carry out a preliminary impact analysis and retain this file; and
  • will take measures to ensure that the overseas recipient will comply with the standard of protection of personal information and privacy stipulated in PRC laws and the Privacy Policy; such as entering into a contract with the overseas recipient specifying the rights and obligations of both parties regarding the protection of personal information.

You acknowledge and agree that ORCOM C&A may transfer your personal information to recipients located outside the PRC in accordance with the Privacy Policy and applicable laws.


In the event that a curriculum vitae containing sensitive personal information, i.e. data concerning your state of health, religious beliefs or trade union membership (or membership of an organization of a similar nature), judicial information and data relating to your racial and ethnic origins, is sent without express written consent authorizing the processing of sensitive data, such consent will be specifically requested in writing. In the absence of written consent within fourteen (14) days, this data will be destroyed.


Your personal information may be retained by ORCOM C&A or another external storage company for no longer than is necessary for the purposes for which the personal information was collected or subsequently processed, in accordance with applicable laws and regulations and the Privacy Policy. Your personal information will be deleted or anonymized after the retention period has expired.


You may at any time submit requests to ORCOM C&A to exercise the rights provided in relation to Personal Information under applicable laws and regulations in the PRC, including the right to obtain access to your Personal Information, rectification and, where provided by law, erasure, restriction of processing and data portability – via the contact details set out below.

You agree that any dispute arising under this policy between you and ORCOM C&A shall be governed by the laws of the PRC, excluding its conflict of law rules.


This website may contain links to other websites managed by third parties. You should carefully review the privacy policies or notices and practices of other websites, as ORCOM C&A cannot control or be responsible for their privacy policies, notices or practices. For links to other websites, please consult the privacy policies of those sites, which may differ from those of this website.


This privacy policy was last updated on April 28, 2023.

From time to time, ORCOM C&A reviews its security and privacy policy and, where appropriate, may modify this policy to reflect changes in legislation and organizational best practices or improvements in functionality dictated by technological developments. In the event of a policy change, the new version will be published on this page of the site. Subject to obtaining your express consent as required by applicable law, the new modified Privacy Policy will apply as of this revision date. Therefore, ORCOM C&A encourages you to periodically review this Statement to be informed of how your information is being protected by ORCOM C&A.


Anyone wishing to receive further information, submit personal proposals, lodge complaints or protests in relation to the organization’s privacy policy or the way in which ORCOM C&A handles personal information, may write to the following e-mail address: