This Policy provides information about the data that Headwind CERAMIC LTD (“Headwind”) collects from you, including how and why Headwind collects, uses and manages that data.
For General Data Protection Regulation (EU 2016/679) and similar regulatory purposes, the data controller is Headwind (see Contact Details). Headwind is based in Hong Kong and is responsible for data collected in relation to the websites, sourcing projects and similar activities that we support and/or manage. Additionally, please note that although Headwind may be principally responsible for looking after your personal data, information may be held in databases that can be accessed by other affiliated entities of Headwind.
Headwind may make changes to this Policy from time to time in order to keep it up to date and compliant with legal requirements. We may notify you about significant changes to this Policy by email or similar electronic communication (using the contact information you last provided to us) or through an alert when you access our systems. Finally, this Policy is not intended to override the terms of any contract that you have with Headwind or related buyers or suppliers or any rights you might have available under applicable data protection laws.
Headwind’s Data Protection Officer (DPO) is the primary point of contact for all issues arising from this Policy, including requests to exercise data subject rights. If you have a complaint or concern about how we use your personal information, please contact our DPO first at firstname.lastname@example.org, and we will attempt to resolve the issue as soon as possible.
You also have a right to lodge a complaint with a data protection authority for your country or region or where an alleged infringement of applicable data protection laws occurs. For your reference:
- A list of EU National Data Protection Authorities: ec.europa.eu/newsroom/article29/item-detail.cfm?item_id=612080
- A list of authorities participating in the Global Privacy Enforcement Network: www.privacyenforcement.net/authorities-listings
- The Office of the Privacy Commissioner for Personal Data, Hong Kong: www.pcpd.org.hk/english/complaints/introduction/introduction.html
Headwind’s websites, policies and other documents may, from time to time, contain links to websites of government authorities and/or Headwind’s partner networks or affiliates. Please note that these websites have their own privacy notices and that Headwind does not accept any responsibility or liability for these notices. Please check these notices before you submit any personal information to these websites.
Collecting Personal Data. Headwind collects your data in a variety of ways, including, but not limited to:
At Trade Shows, Roadshows, Seminars, Conferences or other Sourcing Projects, Headwind asks visitors to complete registration forms that are entered into our systems (including the update/confirmation of data retrieved from previous registrations) and will often ask for business cards and/or other forms of identification for verification purposes.
On headwind.com.hk and similar online platforms, Headwind asks visitors to register in order to use the platform. Headwind also obtains necessary information to support you in: posting and selling products and services as a supplier; inquiring about, purchasing and receiving products and services as a customer; and the general facilitation of the supplier/customer relationship for any transaction on the platform, as appropriate. Headwind also requests other data to generally enhance your profile on Headwind platforms as a supplier or customer, use of messaging functionality and to help address customer service enquiries, complaints, suggestions or feedback.
Systems Tracking Functions
Headwind collects data from other sources, such as public databases, joint marketing partners and other third parties including third party software applications and social media platforms. The data collected through these third party sources will be combined with information we collect through our services where this is necessary to help manage our relationship with you. Headwind will endeavor to confirm with you the accuracy of any personal data gathered from these other sources and will only share or use that data with your consent.
Data Headwind Collects
The personal information we collect includes, but is not limited to:
- Contact and communication details, including your name, addresses, telephone numbers, email addresses, and social media contact details.
o Please note: contact details are typically work-related since our mission is to facilitate B2B trade.
- Business details, for example: job title, role, company name, and company demographics (e.g., number of employees).
- Preferences, including display/language preferences along with other information you provide to personalize any Headwind account or listing.
- Communications, for example: details of calls/messaging with Headwind or with others through any Headwind platform.
- Sale, purchase, service, payment, delivery/performance, including any information needed to facilitate the sale, purchase, payment and/or delivery/performance of goods and services through Headwind in any manner. For example, any information gathered to facilitate (i) requests or orders placed on headwind.com.hk between suppliers and customers or (ii) booking sourcing projects and similar functions organized or supported by Headwind.
- Device and log information, for example: when accessing any Headwind online platform, the Internet domain, IP address, browser software and operating system you use and the date/time of access. Additionally, if you linked to any of Headwind’s online platforms from another website, the address of that website (referrer URL); pages you enter, visit and exit our websites and apps from; your account log-in/online identifier; and any unique device identifiers (e.g., address of the device’s wireless network interface (MAC Address), or mobile phone number used by the device).
- Offline behavioral data, for example: trade shows and exhibitions visitors attended; exhibitors visited; product preferences; and suppliers selected.
Purpose/Use of Personal Data
Headwind uses your personal data to provide you with our products and services, to develop new offerings and to protect Headwind and our visitors, customers and suppliers as detailed below. If you do not provide the data that we request, or prohibit us from using or collecting such data, we may not be able to provide you with any requested products and services.
Headwind will only use data for legitimate business interests, for example, to:
- Create personalized product recommendations on behalf of online suppliers to present to online customers by email or phone.
- Market relevant online and offline services and other products supported by Headwind through print or electronic direct messages (e.g., WhatsApp,), SMS or other platforms including Facebook, LinkedIn and similar third party agencies.
- Create contact lists of any Headwind suppliers, service providers, customers, exhibitors, trade show visitors/attendees and similar clients and partners (together, “Clients and Partners”) who have opted into third party marketing. These lists are segmented based on your preferences, behaviors or demographics and can be rented/sold to verified third party vendors for direct marketing on behalf of their clients.
- Use third party marketing materials from our partners and affiliates to market to other Headwind Clients and Partners who have opted into third party marketing. These materials are segmented based on your preferences, behavior or demographics.
- Create contact lists for surveys and similar market research activities.
- Facilitate inquiries, purchases, services and other transactions between and among Headwind Clients and Partners that take place through Headwind supported platforms and functions.
- Enhance and support Headwind customer service in responding to your comments, feedback, inquiries, questions, and in providing you with the appropriate support to fulfill your needs and requests
- Facilitate internal functions such as auditing, data analysis, and research to improve our products, services and improve your user experience, including providing more relevant customized content to you; and
- Detect, investigate and prevent fraudulent transactions and other illegal activities and protect your rights and property as well as ours.
Additionally, Headwind will use your personal data for legal purposes, such as:
- Ensuring compliance with relevant legal or regulatory obligations;
- Fulfilling obligations under a contract signed between you and us;
- Supporting ‘legitimate interests’ that we have as a business provided it is always carried out in a way that is proportionate and that respects your privacy rights; and/or
- Other clearly defined and limited cases, with your consent.
Securing Personal Data
Headwind is committed to protecting your personal information from unauthorized access, alteration, disclosure and/or destruction. We regularly review our information collection, storage and processing practices, including physical, technological and organizational security measures, to guard against unauthorized access to systems and data stores. We restrict access to personal information to our employees, contractors and agents who: (i) need access to that information to facilitate your business with Headwind and (ii) are subject to strict contractual confidentiality obligations. Headwind also has strong access control mechanisms, such as identity & access management and stringent password policies and, where appropriate, will use technical solutions such as encryption, pseudonymization and anonymization to further protect data.
Please note that you are responsible for the personal information that you choose to share, disclose or submit voluntarily while using any of Headwind’s online or other platforms.
Headwind retains your personal data for as long as is reasonably necessary for the purposes listed in our business arrangement with you and in accordance with this Policy. When your personal information is no longer required, we will ensure it is either securely deleted or stored in a manner where it can no longer be used by Headwind without your consent.
In some circumstances we may retain your personal information for longer periods of time if, for example, we are required to do so (i) to meet legal, regulatory, tax or accounting requirements, (ii) in the event of any complaint or challenge or (iii) we reasonably believe there is a possibility of legal action relating to your personal information or dealings. Under normal circumstances this should not exceed 7 years from the date of Headwind’s last engagement with you.
Sharing Personal Data
Headwind may share your personal information with our employees, contractors, agents and partners, including third parties, to help manage our business and deliver services. In particular, we would only share information with the following third parties, as outlined below:
- Service providers, who perform functions on our behalf such as fulfilling orders, managing our IT and back office systems, delivering packages, sending postal mail and email, removing repetitive information from customer lists, analyzing data, providing marketing assistance, providing search results and links (including paid listings and links), and providing customer services;
- Data protection authorities, regulatory authorities and law enforcement agencies, in Hong Kong, EU and around the world; and
- Other third parties, for the purpose of detecting, preventing or otherwise addressing fraud, security or technical issues, and protecting against harm to the rights, property or safety of our users or the public.
In certain circumstances, Headwind may share your data to a third party if you choose to use their service. Your data may be used by such third party for the purpose of, including but not limited to, fulfilling their service, customer service, ordering and payment processing, improving their products and service, security, direct marketing and other legitimate business purposes. You may also read their privacy notice for more details on their use of your data.
Headwind may also disclose or transfer your data to a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of Headwind business, assets or stock (including any bankruptcy or similar proceedings).
Headwind may use your personal information to send direct marketing communications about our products and services or our related services according to your preferences. We would only do this either with your consent or because we have a legitimate interest to do so, including our latest product announcements and upcoming events. In the latter case, Headwind will limit direct marketing to a reasonable proportionate level and will only send you communications that will be interesting and relevant to you, based on the information we have about you. However, if you no longer want to receive marketing-related emails, SMS, or printed materials, then you may opt out by following the instructions in such communications from us.
Headwind may, from time to time, personalize and highlight certain content, offers and advertisements for you based on information collected and analyzed about you and your viewing habits on our online platforms. This constitutes profiling. We segment our customers and partners by applying selection criteria and business rules using software code (and algorithms) to process relevant data semi-automatically to produce personalized content recommendations.
If you wish to opt-out of receiving personalized content, please contact Headwind’s DPO at email@example.com.
Data Transfers to Non EU Countries or International Organizations
The data that Headwind collects from you may be transferred to, and stored at, a location outside the European Economic Area (EEA). It may also be processed by staff operating outside the EEA who works for us or one of our service providers. We will take all steps reasonably necessary to ensure that your data is treated securely, in accordance with this Policy, and will only transfer your personal information to third parties in other countries that are either:
- Recognized by the European Union as providing an adequate level of data and legal protection,, or
- Protected by appropriate contractual commitments, such as the EU Standard Contractual Clauses, and under this Policy.
In all cases, you have the right to request more information about the safeguards we have put in place. Please contact the DPO.
With respect to your personal information, you always have the right to request:
- Data Access, for example confirming whether Headwind is processing your personal information and requesting a copy of your personal information. You can also request other information about Headwind’s information about you, such as what data we have, what we use it for, who we disclose it to, whether we transfer it abroad, how we protect it, how long we keep it for, what rights you have, how you can make a complaint, where we got your data from and whether we have carried out automated decision making or profiling.
- Data Rectification. You can ask Headwind to rectify inaccurate personal information in our files. In such cases, we may seek to verify the accuracy of the data before and after rectifying it.
- Data Erasure (Right to be Forgotten). You can ask us to erase your personal information, but only when:
o It is no longer needed for the purposes for which it was collected;
o You have withdrawn your consent (where the data processing was based on consent);
o It follows a successful right to object;
o It has been processed unlawfully; and/or
o It is necessary to comply with a legal obligation.
We are not required to comply with your request to erase your personal information if the processing of your personal information is necessary:
o For compliance with a legal obligation; or
o For the establishment, exercise or defense of legal claims.
In the context of marketing, please note that we will maintain a suppression list if you have opted out from receiving marketing content.
- Data Restriction. You can ask us to restrict (i.e. keep but not use) your personal information, but only when:
o Its accuracy is contested, allowing us to verify its accuracy;
o The processing is unlawful, but you do not want it erased;
o It is no longer needed for the purposes for which it was collected, but we still need it to establish, exercise or defend legal claims; or
o You have exercised the right to object, and verification of overriding grounds is pending.
We can continue to use your personal information following a request for restriction, when:
o We have your consent;
o To establish, exercise or defend a legal claims; or
o To protect the rights of another natural or legal person.
- Objection. You can object to any processing of your personal information that has Headwind’s ‘legitimate interests’ as its legal basis, if you believe your fundamental rights and freedoms outweigh our legitimate interests. Once you have objected, Headwind will have an opportunity to demonstrate that compelling legitimate interests override your rights. Please note, however, that this does not apply to objections to the use of your personal information for direct marketing purposes.
- Data Portability. You can ask us to provide your personal information to you in a structured, commonly used, machine-readable format, or you can ask to have it ‘ported’ directly to another Data Controller, but only when:
o The processing is based on your consent or the performance of a contract with you; and
o The processing is carried out by automated means.
- Data Transfers. You can request details about any transfers of your data, whether domestic or international.
To exercise your rights, please contact Headwind’s DPO at firstname.lastname@example.org.
Please note the following if you do wish to exercise any of your rights:
- Identity. Headwind takes the confidentiality of all records containing personal information seriously and reserves the right to ask you for proof of your identity if you make a request to exercise any of your rights.
- IFees.IHeadwind will not ask for a fee to exercise any of your rights in relation to your personal information, unless your request for access to information is unfounded, repetitive or excessive, in which case we will charge a reasonable amount based on the specific circumstances.
- Response Times. Headwind aims to respond to any valid requests as promptly as possible, but please note that the resolution of any issue may take up to one month or longer. We will notify you if any resolution will take longer than one month.
- Legal Exemptions. Some local laws, including in the EU member states, allow Headwind to withhold information from you in certain circumstances, for example where it is subject to legal privilege.
Finally, you have the right to complain to any applicable regulator/supervisory authority. Though, as stated earlier, Headwind humbly requests that such complaints are first provided to us so that we can have an opportunity to address any issues you may have as soon as possible.