Privacy Statement Addendum for Individuals in China

LEM Electronics (China) Co., Ltd. (“we”) respect the privacy of individuals (“you”) who use our products and services. This China Privacy Addendum explains how we collect, use, entrust processors to process, share, store, and transfer your personal information across borders when you use this website, and how you can exercise your related rights.

This Addendum supplements the LEM Privacy Statement posted in www.lem.com and applies specifically to the collection and processing of personal data from individuals located in the People’s Republic of China (PRC), in accordance with the Personal Information Protection Law (PIPL), Data Security Law (DSL), and Cybersecurity Law (CSL).

Please read this Addendum carefully and make sure you understand how we handle your information. By continuing to use this website, you are deemed to have agreed to the contents of this Addendum (including any updates) and to our collection, use, entrustment to processors for processing, sharing, storage, and cross‑border transfer of your personal information in accordance with this Addendum.

Scope of Application

This Addendum applies to personal data collected from individuals located in PRC who:

  • Visit our websites, portals, apps we own or operate;
  • Participate to live events that we host, trade shows and other sites and public events;
  • Purchase or use of our products, solutions, applications or services;
  • Submit contact forms or inquiries;
  • Subscribe to newsletters or marketing communications;
  • Engage with our services or digital content;
  • Prospective and existing customers or business contacts.

Types of Personal Data Collected

We may collect the following categories of personal data:

  • Identifiers (e.g., name, telephone number email address, IP/Mac and physical address, business affiliation and job title);
  • Commercial information (e.g., purchase and transaction history information, products or services of interest);
  • Device information and internet activity (e.g., online identifiers, browsing activity, mobile and web network activity, cookies, analytics, communication history and preferences);
  • Audio or visual information (e.g. photos or videos taken at events);
  • Geolocation data (if enabled);
  • Account credentials (e.g. to attend an online event).

If the above personal data includes sensitive personal information, we will strictly control access to your sensitive personal information, under the principle of data minimization and ensure that staff who may have access to your sensitive personal information have sufficient authorization.

Purpose of Processing

We process your data for the purposes described in the Privacy Statement and for:

  • Providing requested products, services or information;
  • Improving website functionality and user experience;
  • Marketing and promotional communications (with opt-out options);
  • Contract performance and customer relationship management;
  • Conducting marketing and analytics (with opt-out options);
  • Complying with legal obligations.

Legal Basis for Processing

Under PIPL, we process personal data based on:

  • Informed and voluntary consent;
  • Contractual necessity;
  • Compliance with legal obligations;
  • Legitimate business interests, where permitted.

We obtain consent through clear and affirmative actions, such as checkboxes on web forms or banners on our website. You may withdraw your consent at any time by contacting us at privacy@lem.com or using the unsubscribe links provided in our communications.

Cross-Border Data Transfers

Based on LEM Group being a global multinational company, and for unified information management, we will transfer the collected personal information to LEM headquarters (LEM International SA, the “overseas data recipient”) for storage, backup, and processing. If such sharing is legally subject to explicit or separate consent, we will obtain your consent before the sharing takes place. In doing so, we shall:

  • first conduct a Personal Information Protection Impact Assessment (PIPIA);
  • then complete the security assessment for the declaration of outbound data transfer, obtain personal information protection certification, or enter into standard contracts for the cross-border transfer of personal information approved by the
  • Cyberspace Administration of China (CAC) according to applicable laws and regulations (if applicable);
    implement technical and organizational safeguards to protect data.

Third-party data processing outside the country: 

To achieve the purposes described above, we may entrust cloud service providers, third-party telecommunications operators, information technology system, support and storage service providers, and records management providers to collect and process your personal information on our behalf.

If you do not agree to the cross-border transfer of the above personal information, we will not be able to provide the relevant services or respond to your requests or inquiries.

We will sign a data processing agreement with third parties handling data outside the country, clarifying each party's responsibilities and obligations, ensuring that their data processing activities comply with applicable laws and regulations, and taking sufficient technical and organizational measures to protect your personal information security. No entrusted third party may further subcontract or sub‑process the entrusted personal information without our prior written consent.

Data Subject Rights

Individuals in China have the right to:

  • Access and obtain a copy of their personal data;
  • Request correction or deletion;
  • Withdraw consent at any time;
  • Restrict or object to certain processing activities;
  • Close an account;
  • Request reasonable assistance for the portability of the information, to the extent permitted by law and technically feasible.

To exercise these rights, please contact us at: privacy@lem.com

Data privacy and disclosure

We and the overseas data recipient occasionally run activities with our business partners (online or offline, locally or globally). To organize these activities, we may share the minimum necessary personal data with the relevant partners to achieve the purposes described above. Where explicit or separate consent is legally required for sharing, we will obtain your consent before sharing the information.

As a general rule, except as otherwise stated in this Statement, we do not provide your personal data to other personal information processors. If we need to provide your personal data to other processors, we will notify you in accordance with applicable laws, regulations and regulatory requirements and obtain your separate consent.

Data Retention

We retain personal information only for the shortest period of time necessary for the above purposes and delete or anonymize personal information after the retention period has passed, unless otherwise provided for by law or regulation or unless the retention period is extended with the consent of the individual

Compliance Audits

We conduct regular internal audits and, where required, third-party audits in accordance with PIPL and the 2025 Administrative Measures for Personal Information Protection Compliance Audits.

Data Localization

If we are subject to data localization requirements under PIPL (e.g., as a critical information infrastructure operator or exceeding thresholds), we will store personal data within China or obtain the necessary approvals for cross-border transfers in accordance with applicable laws.

Contact Information

For questions or concerns regarding this Addendum or your personal data, please contact our Data Protection Officer at: privacy@lem.com

Address: DPO, LEM International SA, Route du Nant-d’Avril 152, 1217 Meyrin, Geneva, Switzerland

Language Availability

This Addendum is available in both English and Simplified Chinese. In case of discrepancies, the Simplified Chinese version shall prevail for individuals located in the PRC.