Annex CN — Greater China Desk
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PIPL Art. 38 outbound posture, no on-shore data collection, standard contract and CAC filing requirements.
CN.1 Scope
The Greater China Desk supports outbound talent flows to Sercxi's operating corridors. Sercxi does not operate a permanent establishment in mainland China and does not conduct on-shore data collection.
CN.2 PIPL Transfers
Where personal data is exported from mainland China, the transfer relies on one of the permitted mechanisms under Article 38 of the PIPL: the CAC standard contract, third-party certification, or CAC security assessment where thresholds are met.
CN.3 Client Warranty
The Client warrants that any personal data of PRC individuals shared with Sercxi has been transferred lawfully under the PIPL, including any required consent, impact assessment, and filing.
This document is part of the Sercxi governance suite. It does not replace bespoke legal advice for a specific mandate.
For questions or to request the full text of any gated document, contact legal@sercxi.io.