Annex CN — Greater China Desk

For countersigned originals, contact legal@sercxi.io.

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.

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