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Privacy policy

1. Premise

Pursuant to Article 13 of EU Regulation 2016/679 on the protection of natural persons with regard to the processing of their personal data and in relation to the personal data that SUGI International Ltd, Units 2103-09 Two Harbour Square, 180 Wai Yip Street, Kwun Tong, Kowloon, Hong Kong (hereinafter the “Company”) will acquire, we wish to inform you that data relating to you may undergo processing, in compliance with the regulation referred to above, by the Company in connection with contractual relationships entered into with you or such relationships entered into in future.

2. The data controller and data processors

The controller of the personal data is SUGI International Ltd, Units 2103-09 Two Harbour Square, 180 Wai Yip Street, Kwun Tong, Kowloon, Hong Kong (hereinafter the “Controller”).

An updated list of the appointed data processors may be provided on the request of the data subjects and/or users.

3. Personal data sources

Personal data acquired or that will be acquired in connection with contractual relationships are collected directly from the data subject. All the personal data collected are processed in compliance with current legislation and, in all circumstances, with due confidentiality.

4. Reasons for data collection

In order to stipulate and execute the contractual relationship, collecting personal data is also compulsory in order to comply with legal and tax obligations. Refusal to provide such data will make it impossible to establish relationships with the Company. Processing of such data does not require the consent of the data subject.

5. Purposes for which the data are processed and the legal basis of the processing

Personal data are collected or processed for the sole purpose of making it possible to meet the requirements for performing the Company’s business activities and in particular in order to:

  • a) deal with requests for information and/or send estimates requested by the data subject using the form displayed in the section “Contact us”;
  • b) carry out pre-contractual activities and acquire any preliminary information required to stipulate the contract;
  • c) manage the contractual relationship and all activities of an administrative, operational and accounting nature associated with the contract (such as managing orders, invoicing and checking supplier reliability);
  • d) manage any disputes, contractual defaults, notices, transactions, arbitration or litigation;
  • e) fulfil the obligations prescribed by law, regulations, EU regulations and conditions imposed by authorities.

The processing is performed in order to fulfil the contractual/pre-contractual and legal obligations associated with the relationship established by you with the Company.

6. Nature of the provision of data and the consequences of refusal

Providing the Company with personal data is only required for those personal data for which there is a regulatory or contractual obligation, or for personal data necessary for acquiring pre-contractual information resulting from a request made by the data subject. In the event of refusal to provide such “obligatory” personal data, it may be impossible to set up the contract in its entirety. Refusal to provide the personal data for which no such obligation for its provision exists, but which is strictly necessary for executing the contractual relationship, will not in general have any consequences for relationships already in existence, other than it being impossible to perform any operations linked to the personal data in question or to establish new relationships. Refusal to provide personal data relating to performance of further activities not strictly functional for executing contractual relationships may only impede such further activities being performed but without any other consequences.

7. Processing methods

The personal data will be processed using appropriate, legitimate methods and, in all circumstances, in compliance with the aforesaid regulations, using instruments suitable for maintaining the security and confidentiality of the data and the data may also be processed using IT systems designed to store, manage and transmit the data in question.

The processing will be mainly performed by the Company’s in-house organisation under the management and control of appointed Company officers and for the purposes previously stated.

The personal data will be stored in a form that makes it possible to identify the data subject, for a period of time no longer than is necessary for the purposes for which the data have been collected and processed.

8. Duration of processing

The personal data processed will be stored for the time strictly necessary for the purposes of the contractual relationship, and subsequently, in order to fulfil all the legal obligations connected with or arising from the contract entered into by you with the Company.

9. Recipients of the personal data

Without prejudice to the communications required to fulfil a legal, regulatory or EU prescribed obligation, any communications, including by means of simple consultation or making available the personal data relating to you, may be passed on to the following recipients.

  • a) Public bodies, authorities, institutions or supervisory bodies.
  • b) Natural or legal persons providing the following specific services: data processing, logistical and postal services, customer satisfaction surveys, legal, administrative, tax and/or accounting consultancy, organisers of trade fairs and communication events.
  • c) Business intermediaries, banks and credit institutions, financial brokers, natural or legal persons responsible for debt recovery, audits and/or certification of financial statements and quality systems, the Company’s independent partners, agents and representatives, insurers and brokers.

The entities referred to in points a) and c) operate as independent Data Controllers.

We can assure you that, in all circumstances, the data will only be transferred to the aforesaid entities, if these are not in aggregated and anonymous form, when the data in question are necessary and relevant for the stated processing purpose.

The list of the above third parties will be constantly updated and you may have access to it on making such a request to the Company. As a result of the existence of connections with these third parties using remote, computerised or mail methods, the personal data may be made available overseas including to countries outside the European Union, taking account of the relevant authorisation, or on the basis of standard contractual terms and conditions.

The personal data will not under any circumstance be disclosed.

10. Rights of the data subject

You remain entitled to exercise your rights of access to your personal data as prescribed by Article 15 of EU Regulation 2016/679 and the rights set out in Articles 16, 17, 18 and 21 of EU Regulation 2016/679 relating to the rectification, erasure, processing restriction and the right of opposition, in the ways set out in Article 12 of EU Regulation 2016/679.

In more detail, data subjects have the following rights.

  • To withdraw consent previously given.
  • To object to the processing of their data if this is performed on a legal basis other than by consent.
  • To access their own data.
  • To verify and request rectification of their data.
  • To request restriction of processing under certain conditions.
  • To obtain erasure or removal of their data under certain conditions.
  • To receive their own data or have them transferred to another controller.
  • To lodge a complaint to the supervisory authority.

11. The right to lodge a complaint with the Supervisory Authority pursuant to Article 77 of the EU Regulation

If the Company does not provide an answer within the timescale set out in the regulation or if you do not consider its response to your request to exercise your rights to be suitable, you may lodge a complaint with the supervisory authority charged with protecting personal data.

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