Privacy Statement and Personal Information Collection Statement
The Statement applies to all personal data we collect through our official website (www.theeavsgroup.com) (the “Website”).
If you are a citizen of the United Kingdom, we will maintain your personal data as outlined in the Addendum of this Statement.
Please note that the provisions herein may be updated, revised, varied and amended from time to time as we deem necessary. Your continued use of the Website following such revision shall be deemed as your acceptance of the amended Statement. It is your responsibility to check the Statement regularly for any amendments.
- Collection of Personal Data
The types of personal data we collect from you will depend on the specific type of facilities, services and/or products as requested by, or provided to, you. The types of personal data may include (without limitation) the following:
- your personal information (e.g. your name, telephone numbers and email addresses);
- your business information (e.g. company name, business title and associated contact information);
- your interests, personal preferences or comments; and/or
- information when you use the Website or other facilities, services and/or products (e.g. behavioural information, location information, browser details and IP addresses).
All personal data collected by us through the Website or through any other medium are to be provided voluntarily by you and you are not obliged to supply the personal data, however if you do not provide your personal data (whether compulsory or optional) we may not be able to provide the relevant services to you.
- Purposes of Collection
The purposes for which your personal data are collected and used may include (without limitation) one or more of the following purposes:
- following up on comments, inquiries and complaints that users submit to the Website;
- understanding users’ needs so as to provide better facilities, services and/or products;
- collecting data for identity verification and record and maintaining contact lists for correspondence;
- promoting, improving and/or further the provision facilities, services and/or products of the Group;
- with your consent, marketing or promoting any of facilities, services and/or products of the Group (e.g. sending you updates on our latest offers and promotions in relation to any of facilities, services and/or products from time to time);
- evaluating the effectiveness of our advertising and marketing campaigns;
- recruitment and human resource management including online job applications;
- communicating with investors and/or potential investors of the Group;
- monitoring use of the Website to help its further development;
- compiling statistics about our users or customers to analyze site usage or aggregated consumer behavior;
- making disclosure when required by law, regulation, or court order of any jurisdiction, and/or as requested by any government, regulatory or law enforcement authority or administrative organisation, which may be within or outside the Hong Kong Special Administrative Region of the People’s Republic of China (“Hong Kong”);
- establishing legal claims or defences, obtaining legal advice, and/or exercising, defending and/or protecting the rights or properties of any member of the Group, including identifying, contacting or bringing legal action against any person who may be causing interference with such rights or properties (whether intentionally or otherwise) or where any other person could be harmed or property of any other person could be damaged by such interfering activities;
- for the use by any member of the Group in connection with any of the above purposes and/or any of services and products that any member of the Group may offer or supply to you from time to time; and/or
- any other incidental or associated purposes relating to the above, or any other purpose to which you may from time to time agree.
If you are under the age of 18, you must ask your parent or guardian before providing any personal data to us.
- Date Retention
We will only retain your personal data for as long as reasonably necessary to fulfill the purpose for which the data was collected unless the personal data is also retained to satisfy any applicable statutory or contractual obligations. Personal data which no longer required will be destroyed.
- Disclosure and Transfer of Personal Data
We will take all practicable steps to keep your personal data confidential but for any one or more purpose(s) named under the section ‘Purposes of Collection’. We may transfer/assign your personal data to or exchange such data with third parties located within or outside Hong Kong, and your personal data may be transferred within or outside Hong Kong. These third parties may include the following:
- subsidiaries, associated and/or related companies of The Eav’s Group Limited;
- agents, contractors and third party service providers authorised or engaged by the Group or its affiliate who provide administrative, data processing, research and marketing, distribution, telecommunications, professional or other services to the Group;
- any person to whom we are under an obligation to make disclosure under the requirement of any law binding on us or for the purposes of any guidelines or codes of practice issued by regulatory or other authorities with which we are reasonably expected to comply; and
- our professional advisers.
Personal data may be transferred to, stored or processed by the above-named parties which may be located in countries outside of your own for the purpose(s) named under the section ‘Purposes of Collection’, and may be accessible to law enforcement and national security authorities of that jurisdiction. Any transfer will be made subject to compliance with the law.
We may also transfer personal data to a purchaser or transferee (or proposed purchaser or transferee) of any of the Group’s business or the business of a particular division or line of our business, or any such business of an affiliate (whether through a sale of assets or shares), including for the purposes of any due diligence exercise, subject in each case to our compliance with all applicable legal and regulatory obligations.
Unless expressly stated in this Statement or with prior consent, personal data collected from you will not be disclosed to any third party other than the above-named parties.
- Security of Personal Data
In order to ensure the correct use and to maintain the accuracy of the personal data collected from you, as well as preventing unauthorised or accidental access, processing, erasure or other use of the personal data, we have put in place appropriate security measures to safeguard and secure the personal data we collect.
Although we will do our best to protect your personal data, we cannot guarantee the security of your personal data transmitted to the Website. Any transmission of personal data is at your own risk. Once we have received your personal data, we will use appropriate security measures to seek to prevent unauthorized access or disclosure.
- Log Files
When you visit the Website, data relating to your visits, including but not limited to your IP address, domain name, browser type and access time will be collected for preparing general statistics on the usage of the Website to improve the effectiveness of our marketing and promotional activities. This information does not identify you as an individual. No personal data will be collected.
- Links to other websites
- Data Access and Correction
You have the right (subject to various exceptions and in accordance with data protection legislation in your country) to:
- check what kinds of personal data about you the Group holds;
- access the personal data about you the Group holds;
- require the Group to correct any personal data which is inaccurate; and
- request a copy of this Statement.
Additional rights may be available to you depending on the location of your residence or of our operations. To exercise any of these rights, please contact us using the details under the section ‘Contact us’ below.
It is important to make sure your personal data is kept up to date. If you wish to change or modify your information previously provided, please contact us using the details under the section ‘Contact us’ below. We may ask you to authenticate your identity in order to protect the safety of your personal data.
To the extent permitted by relevant laws and regulations, we reserve the right to refuse unreasonable requests (for example, requests which infringe the privacy of others). To the extent permitted by relevant laws and regulations, we reserve the right to charge a reasonable fee for the cost of processing any request set out above.
- Use of Personal Data in Legal Proceedings
If it becomes necessary that we have to take action against you for any reason whatsoever including but not limited to recovering from you any money you owe us, you expressly agree that the personal data provided by you can be relied upon in identifying and take legal action against you.
The Statement is designed to provide compliance with all relevant applicable laws and regulations, in particular those our businesses are subject to. We recognize that certain laws and regulations might be modified to require more stringent standard than those described in the Statement, in which case the more stringent standards shall apply. If applicable laws and regulations provide for a lower level of protection of personal data than the Statement, then the Statement shall prevail.
As an international business with operations in different parts of the world, we may need to disclose your personal data when required by relevant law or court order, or as requested by other government or law enforcement authorities. This also applies when we have reason to believe that disclosing your personal data is necessary to identify, investigate, protect, contact or bring legal action against someone who may be causing interference with our rights or properties (including our Website), or to others, whether intentionally or otherwise, or when anyone else could be harmed by such activities.
- Contact us
If you have any questions about the Statement or our privacy practices, or wish to exercise any of the individual rights outlined in the section ‘Data Access and Correction’ above, please contact us as follows:
Full name of legal entity: The Eav’s Group Limited
Address: 3901 The Hopewell Centre, 183 Queen’s Road East, Wan Chai, Hong Kong SAR
Contact: +852 2855 2289
Email address: email@example.com
This Addendum applies in circumstances where the privacy practices of The Eav’s Group Limited and its subsidiaries, associated and/or related companies (collectively, the “Group”, “our”, “we” or “us”) are subject to the Data Protection Act 2018 (the “Act”). This will be the case if you are based in the United Kingdom during your interactions with us.
This Addendum should be read in conjunction with the Statement of the Group. In this Addendum, we set out further information on our processing activities and details of the rights which you have under the Act. We reserve the right, at our discretion, to change, modify, add, or remove any parts from this Addendum at any time. You are encouraged to review this Addendum from time to time for updates periodically. Your continued use of our Website after such revisions are posted means you elect to accept these changes.
- Purposes for which we will use your personal data
We can collect personally identifiable information about you as more particularly described in section under ‘Collection of Personal Data’ of the Statement and the purposes for collection and use of these personal data are described in section under ‘Purposes of Collection’ of the Statement.
Personal data will only be processed if there is at least one lawful basis as follows:
- Legitimate interest – the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).
- Performance of Contract – processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
- Comply with a legal obligation – processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.
- Children’s Data
We do not collect personal data about children under the age of 16. In the event any personal data of children under the age of 16 were collected, we will delete the data when any individual contacts us under section ‘Contact us’ of the Statement.
If you are under the age of 18, you must ask your parent or guardian before providing any personal data to us.
- International Transfer
We share your personal data within the Group. This will involve transferring your data outside the United Kingdom.
Whenever we transfer your personal data out of the United Kingdom, we will ensure that appropriate measures are in place to comply with our obligations under applicable law governing such transfers.
Please contact us using the details under the section ‘Contact us’ of the Statement if you want further information on the specific measures used by us when transferring your personal data out of the United Kingdom.
- Retention Period
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
- Your Rights
Under the Act, you have the following rights, which apply in certain circumstances and subject to certain restriction:
- Request access to your personal data. This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
- Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
- Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
- Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
- Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
- If you want us to establish the data’s accuracy.
- Where our use of the data is unlawful but you do not want us to erase it.
- Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
- You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
- Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
- Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you.
If you wish to exercise any of the rights set out above or if you have any questions about this Addendum, please contact us.