Privacy Policy (隐私政策)

Last Updated: May 11, 2022


Chinese (中国人)
Spanish (Español)


Introduction (介绍)

We at Sutherland Global Services, Inc. and our Affiliated Companies worldwide ("Sutherland" or “Company”) are the controllers of personal information collected on this website and through offline or other means during business activities. We collect Personal Data from individuals with whom we interact for business purposes, including but not limited to contact individuals within business customer/prospect and vendor organizations, job candidates, and employees and their beneficiaries/plan participants. We are committed to respecting your privacy and recognize the need for appropriate protection and management of any personally identifiable data (“Personal information” or "Personal Data") you share with us.

Sutherland Global Services, Inc.和其全球的附属公司(“萨瑟兰”或“公司”),是通过本网站以及在线下商业活动期间或其他方式收集个人信息的相关方。我们收集与我们有业务往来的个人的相关信息,包括但不限于联系商业客户/潜在客户和供应商组织内的个人、职位候选人、雇员及其受益人/计划参与者。我们致力于尊重您的隐私,并认识到我们需要适当保护和管理您共享给我们的任何身份信息(“个人信息”)。

“Affiliated Companies” means with respect to any specified person or entity, any other person or entity Controlling, Controlled by or under common Control with such entity, where “Control” with regard to an entity, means the beneficial, equitable or legal ownership, either directly or indirectly, of more than fifty percent (50%) or more of the capital stock (or other ownership interest, if not a corporation) of such entity ordinarily having voting rights, or effective control of the activities of such entity regardless of the percentage of ownership.


Sutherland’s Privacy Policy outlines how Sutherland collects, uses, shares, and secures your Personal Data on a global basis where Sutherland is the controller of your Personal Data, as defined by applicable privacy laws. This policy also describes your choices and rights regarding your Personal Data.



Personal Data(个人信息)

Personal Data is any data relating to an identified or identifiable natural persons, excluding the information processed anonymously, including but not limited to the name, address, phone number and bank account number of natural persons.


What Personal Data We Collect and How We Use It(收集个人信息范围及使用)

Sutherland processes your Personal Data to ensure the efficiency and effectivity of Sutherland business activities and relationships, conduct business and commercial transactions, maintain the recruitment/employment relationship, and plan and conduct marketing.


Below is a description of the Personal Data Sutherland may have collected and/or used over the last 12 months:


Category of Personal Data(个人信息种类)


Purpose and Uses (目的和用途)



Name, contact information (postal address, email address, phone number), Internet Protocol address.(姓名,联系方式(通讯地址,邮箱,电话号码),网络通讯地址)

Sutherland may use Identifiers to fulfil a contract with the organization for which you work, or to conduct business activities such as marketing and business communications. Sutherland may also process Identifier information to fulfil legal requirements and protect Sutherland’s legal and business interests. (萨瑟兰可以使用标识信息来履行与您工作的组织的合同,或者进行商业活动,如市场营销和商业交流。萨瑟兰也可以处理标识信息以满足法律要求并保护萨瑟兰的法律和商业利益)

Sutherland conducts direct marketing with your consent. Otherwise, Sutherland processes Identifiers for Contract or Legal reasons. (萨瑟兰在您同意的情况下进行相关活动。否则,萨瑟兰将根据合同或法律原因处理标识信息。)

Customer Records Information(客户档案信息)

Name, signature, employment information (title, role), contact information(姓名,签名,员工信息(头衔,岗位信息)联系方式)

If you currently work or previously have worked for a business customer or vendor organization, we may have collected information about you in our Customer Records in order to fulfil a contract with your organization, or to conduct business activities such as marketing and business communications. (如果您目前或以前为商业客户或供应商组织工作,我们可能会在客户记录中收集关于您的信息,以履行与您的合同,或进行商业活动,如营销和商业沟通。)

Sutherland conducts direct marketing with your consent. Otherwise, Sutherland processes Customer Records Information for Contract or Legal reasons. 萨瑟兰在您同意的情况下进行相关活动。否则,萨瑟兰将根据合同或法律原因处理标识信息。)

Commercial Information(商业信息)

Products or services purchased or other purchasing or consuming histories or tendencies(购买的产品或服务或其他的购买历史)

Sutherland may collect Commercial Information in order to customize and plan marketing activities, make business decisions, and make financial and resource forecasts. (萨瑟兰收集商业信息,可能为了策划市场相关活动,作出商业决策,并作出财务和资源预测)

Sutherland conducts these activities with Legitimate Business Interests, and in some cases to fulfil Contracts or for Legal reasons. (萨瑟兰从事这些活动是出于合法的商业利益,在某些情况下是为了履行合同或出于法律原因)

Internet or Other Electronic Network Activity(网络或其他电子信息)

Browsing history, search history, information regarding interaction with our networks, websites and advertisements(浏览历史,搜索历史,与我们的网络交互的有关信息,网站和广告信息)

To better manage and design our websites, customize and serve ads, perform website analytics, and manage marketing activities, Sutherland collects Internet or Other Electronic Network Activity information. As individuals access Sutherland online applications and networks, Sutherland tracks and manages access in order to maintain security. (为了更好地管理和设计我们的网站,定制广告服务,执行网站分析,并管理营销活动,萨瑟兰收集互联网或其他电子网络活动信息。当个人访问萨瑟兰的在线应用程序和网络时,萨瑟兰会跟踪和管理访问,以维护网络安全)

Sutherland collects this network, online and online advertising information for its Legitimate Business Interests. (萨瑟兰收集网络和在线信息是为其合法的商业利益。)

Geolocation Data(地理位置数据)

“Non-Precise” Geolocation information at the country level based on IP address(基于IP地址的国家级别的“非精确”地理位置信息)

Sutherland may recognize the country from which a web visitor comes to a Sutherland website through IP address in order to customize a web visitor’s experience, manage security and protect against fraud, and fulfil requests. Web visitors may also provide Sutherland country location in order to establish web experience preferences. (萨瑟兰可以识别网络访问者通过IP地址访问萨瑟兰网站的国家,以定制网络访问者的体验,管理安全和防范欺诈,并满足请求。网站访问者也可以提供萨瑟兰国家位置,以建立网络体验偏好。)

In some cases, Sutherland obtains Consent for country-level location data. In other cases, Sutherland uses this information for Legitimate Business Interests or to fulfil Contracts with web visitors. (在某些情况下,萨瑟兰获得了国家级位置数据的许可。在其他情况下,萨瑟兰将这些信息用于合法的商业利益或履行合同的需求)

Professional or Employment-Related Information(专业或就业相关信息)

Name, contact information, job history, job title, performance information, education history, IP Address, CV or resumes, background check data (such as criminal and financial background checks), racial or ethnic origin, data related to compensation.(姓名,联系方式,工作经历,绩效表现,教育经历,IP地址,简历信息,背调信息(例如有无犯罪历史和银行信息),种族或薪资信息

In order to find, communicate with (i.e. sending emails and/or SMS messages), evaluate and hire the right job candidates, Sutherland collects and uses Professional or Employment-Related Information. (为了寻找、沟通(如发送电子邮件和/或短信)、评估和聘用合适的职位候选人,萨瑟兰收集和使用专业或就业相关信息。)

Sutherland collects and uses this information to support Legal requirements and claims and operate business activities under its Legitimate Business Interests. Job candidates may provide Consent for some data processing activities. (萨瑟兰收集并使用这些信息来支持法律要求和声明,并在其合法商业利益下开展业务活动。求职者需要同意某些数据的处理活动)

Education Information(教育信息)

Title, certifications(头衔,证书)

In addition to education information provided in the recruiting contexts, Sutherland captures Education Information about business contexts during the normal course of communication; for example, where a contact individual provides title or certification information in the signature line of emails. (除了在招聘环境中提供的教育信息,萨瑟兰还在正常的沟通过程中获取商业环境的教育信息;例如,联系人在电子邮件的签名行中提供标题或认证信息。)

Sutherland collects and uses this information to fulfill Contracts with vendor and business customer organizations; and in the recruiting context with Consent or for its Legitimate Business Interests. (萨瑟兰收集并使用这些信息来履行与供应商和商业客户组织的合同;以及在招聘时征得其同意或出于其合法商业利益。)

Sutherland does not, as a practice, collect Personal Data revealing political opinions, religious or philosophical beliefs, genetic information, or sex life/sexual orientation.


If Sutherland intends to use or transfer Personal Data for purposes beyond those for which it was originally collected or subsequently authorized by you, or for purposes incompatible for those uses, Sutherland will offer you the opportunity to affirmatively opt in.


In addition to the above, Sutherland is the controller of Personal Data for employees, contractors and other Sutherland workers. Sutherland uses this Personal Data, which can include sensitive personal information, to maintain the employee/worker Contract and for its Legitimate Interests.


The legal grounds we have to use your personal information(我们使用您个人信息的法律依据)

Sutherland generally collects only the personal information necessary to fulfil your request. Where additional, optional information is sought, you will be notified of this at the point of collection.


The relevant data privacy laws in the Peoples’ Republic of China where applicable, allows us to process personal information, so long as we have a ground under the law to do so. As a result, when we process your personal information, we will rely on one of the following processing conditions:


  1. Performance of a contract: this is when the processing of your personal information is necessary in order to perform our obligations under a contract entered with you;


  2. Legal obligation: this is when we are required to process your personal information in order to comply with a legal obligation, such as keeping records for tax purposes or providing information to a public body or law enforcement agency;


  3. Your consent: we may occasionally ask you for specific and separate permission to process some of your personal information, and we will only process your personal information in this way if you agree for us doing so. You may withdraw your consent at any time by contacting


Sutherland only collects “sensitive personal information” when the relevant individuals voluntarily provide us with this information or where such information is required or permitted to be collected by law. Sensitive information includes personal information regarding a person’s race, ethnicity, political beliefs, religious beliefs, criminal record, biometric identification, specific identity, medical health, financial account and whereabouts and tracks. Please use your discretion when providing sensitive information to Sutherland. Under any circumstances,  you should not provide yours or any third parties’ sensitive personal information to Sutherland unless we shall separately notify you (and these third parties) and you (and these third parties)  have given us your (and these third parties’) explicit  consent  for Sutherland to use or process  your (and these third parties’)  sensitive personal information for legitimate and necessary business purposes and you (and these third parties)  have also consented for us to the transfer and  store such sensitive personal information  in Sutherland databases.  If you have any questions about whether the provision of sensitive information to Sutherland is, or may be, necessary or appropriate for particular purposes, please contact Sutherland at

萨瑟兰仅在相关个人自愿向我们提供此类信息,或者法律要求或允许收集此类信息时,才会收集“敏感个人信息”。敏感个人信息包括有关个人种族、民族、政治信仰、宗教信仰、犯罪记录、生物识别、特定身份、医疗健康、金融账户以及行踪轨迹等的个人信息。在向萨瑟兰提供敏感个人信息时,请您自行决定是否提供。在任何情况下,您都不应向萨瑟兰提供您或任何第三方的敏感个人信息,除非我们将单独通知您(和这些第三方),并且您(和这些第三方)已明确同意萨瑟兰出于合法和必要的商业目的使用或处理您(和这些第三方)的敏感个人信息,并且您(以及这些第三方)也同意我们在萨瑟兰数据库中传输和存储此类敏感个人信息。如果您有对于特定目的是否必要或可能是必要的或适当的需向 萨瑟兰提供敏感信息而有任何疑问,请通过 与萨瑟兰联系。

Sources of Personal Data(个人信息的来源)

We have collected the above categories and types of personal data directly from individuals through our website and through social media sites such as LinkedIn, and through business interaction and documents such as our contracts and other shared documents. In a few limited cases, Sutherland may have received Personal Data with data subject consent from a third party, such as a third-party recruiter or job site who has permission to pass on job candidate details to Sutherland.


How We Share Personal Data (我们如何共享个人信息)

We do not share personal information with unaffiliated third parties, except as necessary for our legitimate professional and business needs and to the extent permitted by law, to carry out your requests, and/or as required or permitted by law or professional standards. This would include:


  1. We may share your Personal Data with third-party service providers under contract to us to assist in our business activities, which may include but are not limited to marketing, advertising our product/service offerings, recruiting, and maintaining and improving our service offerings. We will inform you the supplier’s name and contact details, purposes and methods of processing, and the type of personal information involved, and obtain your separate consent. These service providers are authorized to use your Personal Data only as necessary to provide these services to us. Sutherland does not sell Personal Data or provide Personal Data to third parties for their own uses in the non-performance of the foregoing service.


  2. Some third-party advertising or analytics cookies can be considered a “sale” under some definitions, and you can opt out of this sharing through our cookie consent banner that may appear in a ribbon on our website pages, or by following instructions provided in our full Cookies Policy. In addition, though Sutherland does not sell Personal Data in any way, you can opt out of any future sharing by emailing this request to  

    在某些定义下,某些第三方广告或分析 Cookie 可被视为“销售”,您可以通过出现在我们网站页面上功能区中的 Cookie 同意横幅,或按照我们完整的 Cookie 政策中提供的说明,选择退出此信息共享。此外,尽管 萨瑟兰不会以任何方式出售个人数据,但您可以通过向 发送邮件的方式来选择退出任何未来的信息共享。

  3. Sutherland may also disclose your Personal Data as required by law, such as to comply with a subpoena or other legal process, when Sutherland believes in good faith that disclosure is necessary to protect Sutherland’s rights, protect your safety or the safety of others, investigate fraud, or respond to a government request.


  4. If we are reorganized or sold to another organization: Sutherland may also disclose personal information in connection with the sale, assignment, or other transfer of the business. In this case, we will inform you the name and contact details of the receiving party, the receiving party will keep processing your personal information on the same purposes and ways.  


  5. Audits: disclosures of personal information may also be needed for data privacy or security audits and/or to investigate or respond to a complaint or security threat.


In addition, if you are located in People’s Republic of China, Sutherland may transfer certain personal information outside of China to companies working with us or on our behalf for the purposes described in this Privacy Statement to the extent permitted by law, and subject to the fulfillment of the regulatory requirements of the applicable laws. If we do this, your personal information will continue to be protected and we will comply with the relevant regulations regarding the provision of cross-border personal information by relevant Chinese authority. For example, pass the safety assessment, ask for your consent to the transfer of personal information across borders, inform you of the name of the overseas receiver, the purpose of processing, the way it is processed, the type of information transmitted, etc., or to implement security measures such as data de-identification prior to cross-border data transfer.



You may have a choice to receive some types of communications from Sutherland. For example, you may sign-up and consent to receive email, SMS messages or newsletter communications from Sutherland. If you would like to discontinue receiving these communications, you may update your preferences by using the “Unsubscribe” link found in emails or by contacting Sutherland using the information in the “Contact Data” section of this Policy. You may also have an opportunity to choose whether some cookies are set on your device. See our full Cookie Policy for more information.


More About our Website (关于我们网站的更多信息)

Cookies and Other Tracking Technologies (Cookies 和其他追踪技术)

This site uses cookies to store information on your computer. Some are essential to make Sutherland site work; others help Sutherland improve the user experience. A "cookie" is a small text file that may be used, for example, to collect data about website activity. Some cookies and other technologies may serve to recall Personal Data previously indicated by a web user. For greater details, please refer to the Sutherland Cookie Policy to learn more.


If you wish to opt out of interest-based advertising, click here or if located in the European Union, click here. Please note you will continue to receive generic ads.


Log Files(记录文件)

Log files may record data such as Internet domain and host names; Internet protocol (IP) addresses; browser software and operating system types; internet service provider, clickstream patterns; the files viewed on Sutherland website (e.g., HTML pages, graphics, etc.), referring and exit pages and dates and times that Sutherland site is accessed to analyze trends in the aggregate and administer the site.



Wherever your Personal Data may be held within Sutherland or on its behalf, Sutherland takes commercially reasonable and appropriate steps to protect the Personal Data that you share with Sutherland from unauthorized access or disclosure.


Although we use appropriate security measures once we have received your personal data, the transmission of data over the internet (including by e-mail) is never completely secure. We endeavor to protect personal data, but we cannot guarantee the security of data transmitted to or by us.


Where a personal information security incident arises, we shall respond to the incident, assess the likely impact of the incident, and take necessary actions to bring the incident under control. Where necessary, we will report to the appropriate authority, notify you of the incident and provide relevant information, as may be required under applicable laws and regulations.


If you have any questions about the security of your Personal Data, you can contact Sutherland at


Data Hosting and Retention(数据托管和保留)

Sutherland is a global company and may store your Personal Data in data centers around the world. Regardless of location, Sutherland protects your data with similar controls and safeguards. For example, if Sutherland transfers data from the European Union or from other countries (such as China) requiring additional measures to allow the data transfer, Sutherland uses Standard Contractual Clauses among other measures to provide adequacy ensuring that your data protection rights travel with your data. Sutherland will not store your data longer than necessary for the purpose for which we have processed your data. How long we retain your data depends on the type of data and the purpose for which we process your data. Contact us at for more information about data retention.

萨瑟兰是一家全球性公司,可能将您的个人信息存储在世界各地的数据中心。无论位于何处,萨瑟兰都会通过类似的控制和保护措施保护您的数据。例如,如果萨瑟兰从欧盟或其他需要采取额外措施以允许数据传输的国家(如中国)传输数据,萨瑟兰将使用标准合同条款以及其他措施以提供保护的充分性,以确保您的数据保护权利随数据一起传输。萨瑟兰存储您的数据的时间不会超过我们处理您的数据所需的时间。我们保留您的数据的时间取决于数据类型和我们处理您数据的目的。请通过 联系我们,了解有关数据保留的更多信息。

Children's Privacy(未成年人的隐私)

Sutherland’s website is a general audience website. Accordingly, Sutherland does not intend to collect Personal Data from anyone Sutherland knows to be under 16 years of age.  


If we learn that we have collected personally identifiable information from an individual under 16 years of age, we will take reasonable steps to delete such information from our files as soon as is practicable. Please contact us via the TrustArc link below if you believe we have any information from or about an individual under the age of 16.


Data Subject Rights(数据主体的权利)

Depending on where you live, you may have certain rights regarding your Personal Data. To exercise any of the following rights, please contact us at, complete an individual rights request using this Individual Rights Form, or if you are a California resident and calling from the US you can call us toll free at 1-866-I-OPT-OUT (1-866-467-8688) and enter Service Code 843.


Note that there may be exceptions and limited applicability to some individual data rights, and Sutherland may not be required or able to fulfill your request. In most cases, we will respond to your request within 30 days unless legal requirements dictate otherwise. Below is a summary of individual data rights you may have, depending on local requirements:


Right to Know and Right to Request Information(知情权和索取信息权)

You may have the right to request that we disclose what personal information we collect, use, disclose or sell.  You have the right to request information about the personal information we’ve collected about you within the last twelve months, and you may have the right to receive a machine-readable copy of your Personal Data and/or have us provide your Personal Data to a third party.  You may request to know if we have collected, sold or shared with third parties, including the following information:


  • The categories of personal information we have collected about you;
  • 我们收集的关于您的个人信息的类别;
  • The categories of sources of personal information we collected about you;
  • 我们收集的关于您的个人信息来源的类别;
  • Our business or commercial purpose for collecting or selling personal information about you;
  • 我们收集或出售您个人信息而涉及的业务或商业目的;
  • The categories of third parties with whom we share personal information;
  • 我们共享您个人信息的第三方的类别;
  • The specific pieces of personal information we have collected about you;
  • 我们收集的关于您的具体个人信息;
  • Whether we have sold your personal information and if so the categories of personal information that each category of recipient purchased; and
  • 我们是否出售了您的个人信息,如果是,出售的个人信息类别;及
  • Whether we have disclosed your personal information for a business purpose and if so, the categories of personal information that each category of recipient received.
  • 我们是否出于商业目的披露了您的个人信息,如果是,披露的个人信息的类别。

Right to Request Correction or Deletion(要求更正或删除的权利)

  • If you believe that we have some Personal Data about you that is incorrect, you can request that we update or correct that information.
  • 如果您认为我们提供的有关您的某些个人信息是不正确的,您可以要求我们更新或更正这些信息。
  • You have the right to request that we delete your personal information. Under certain circumstances we may be unable to delete your personal information, for example, to comply with legal obligations, or to complete a business transaction that you have requested. 
  • 您有权要求我们删除您的个人信息。在某些情况下,我们可能无法删除您的个人信息,例如,为了遵守法律义务,或完成您要求的商业交易。

Right to Object, Withdraw Consent, and Data Portability (反对、撤销同意和数据可转移的权利  )

  • You may have the right restrict (stop any active) processing of your personal data.
  • 您有权限制(要求停止任何活动 )处理您的个人数据
  • In addition, you canobject to the processingof your personal data in some circumstances (in particular, where we don’t have to process the data to meet a contractual or other legal requirement, or where we are using the data for direct marketing).
  • 此外,您可以在某些情况下反对处理您的个人信息(特别是,无须处理个人信息便可满足合同或其他法律要求的情况,或在我们将数据用于直接营销的情况下)。

Right to Non-Discrimination(不受歧视的权利)

  • You have a right not to receive discriminatory treatment for exercising your privacy rights.
  • 您有权不因行使隐私权而受到歧视。

Right to Complain to a Regulator(向监管机构投诉的权利)

  • If you have unresolved concerns, you may have the right to complain to the data protection authority where you live, work or where you believe a breach may have occurred.
  • 如果您有未解决的问题,您有权向您居住、工作或您认为可能发生违规行为的数据保护机构投诉。
  • In Canada, you may contact the Office of the Privacy Commissioner of Canada (OPC) to help resolve a privacy concern you have at
  • 在加拿大,您可以联系加拿大隐私办公室(OPC),在 帮助您解决。
  • In the European Union, find your Data Protection Authority’s contact information at
  • 在欧盟,请通过以下网址查找数据保护机构的联系信息:
  • In the United Kingdom, you can make a complaint about us to the UK Information Commissioner’s Office (ICO) at
  • 在英国,您可以通过向英国信息专员办公室(ICO)投诉。
  • In the Philippines, you can contact the National Privacy Commission at
  • ·•在菲律宾,您可以通过联系国家隐私委员会。
  • You may also contact the privacy regulator in your country, state, or province. Most privacy regulators can be contacted online using the resources provided at
  • 您也可以联系所在国家、州或省的隐私监管机构。大多数隐私监管机构都可以使用网站提供的资源在线联系。

You can make a request or exercise these rights by contacting Sutherland at and we will make all reasonable and practical efforts to comply with your request, so long as it is consistent with applicable law and professional standards. These rights may be limited, for example if fulfilling your request would reveal personal data about another person, where they would infringe the rights of a third party (including our rights) or if you ask us to delete information which we are required by law to keep or have compelling legitimate interests in keeping. We will inform you of relevant exemptions we rely upon when responding to any request you make.

您可以通过联系萨瑟兰privacy@sutherlandglobal.com提出请求或行使这些权利,在符合适用法律和专业标准时,我们将尽一切合理和实际的努力来履行您的请求。这些权利可能会受到限制,例如,如果满足您的请求会泄露有关他人的个人信息,侵犯第三方权利(包括我们的权利) 或您要求我们删除法律要求我们保留的信息和我们保留的有令人信服的合法利益的信息时。因此在回应您的任何请求时,我们将告知您我们所依赖的相关豁免条例。


Sutherland is committed to privacy. Protecting your privacy online is an evolving area, and this website is constantly evolving to meet these demands.


If you have any comments or questions regarding Sutherland’s Privacy Policy, please contact Sutherland at While Sutherland cannot guarantee privacy perfection, Sutherland will address any issue to the best of our abilities as soon as possible.


If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third-party dispute resolution provider (free of charge) at


International Personal Data Transfers Outside the EEA(欧洲经济区以外的国际个人数据转移  )

Sutherland may, subject to applicable law, transfer your information outside the country where you are located and to where information protection standards may differ (e.g., your information may be stored on servers located in other jurisdictions). We will utilize appropriate safeguards governing the transfer and usage of your personal information such as Standard Contractual Clauses pursuant to Article 46 of the GDPR. If you would like further detail on the safeguards we have in place you can contact us directly as described in this Privacy Notice.


Contact Data(合同数据)

You can contact our Global Chief Data Protection Officer, Canadian Privacy Officer, EU Data Protection Officer, and the global privacy team generally at:


Sutherland Data Privacy Office
Attention. Chief Data Privacy Officer
Sutherland Global Services Inc.,
1160 Pittsford Victor Road
Pittsford, NY 14534

Changes to This Privacy Policy(本隐私政策的更改)

You should review this Privacy Policy on a routine basis as Sutherland reserves the right change this Privacy Policy, or any portion thereof, when we make changes to this statement, we will revise the “updated” date at the top of this page, an updated version of our Privacy Policy will be posted to our website.