Privacy Policy
Overview
In this policy, "we" refers to Jade Premium Company Limited and its affiliated companies involved in the collection, use, sharing, or otherwise processing of personal information, while "Users" refers to individuals who access the Website. The "Website" refers to www.jadepremium.com.hk .
We take Users’ privacy very seriously. The principles of responsibility, fairness, and transparency guide our collection and use of personal information. This policy also informs Users of their rights and choices regarding their personal information. To uphold these values, this policy explains our purposes, methods, and scope concerning the collection and use of personal information, while striving to present the most relevant information to Users in a clear and easily accessible manner, reflecting our relationship with Users.
We encourage Users to read this policy carefully and confirm their full understanding before using our services. By commencing use of our services or continuing to use them following updates to our privacy policy (which we will promptly notify Users of), Users are deemed to have fully understood and agreed to all contents of this policy, including any updated versions.
1. How We Obtain User Personal Information
1.1 Users may provide us with their personal information through business collaborations or by participating in our marketing activities. Additionally, Users may share their personal information when communicating with us via our official website or social media pages.
1.2 We may also obtain Users' personal information from third parties, including vendors involved in marketing activities or our suppliers, referred to as “indirect channels” in this policy.
2. How We Collect and Use Personal Information
In this policy, "personal information" refers to various types of information that can identify a specific individual, whether recorded electronically or otherwise, either alone or in conjunction with other information. We will only collect and use Users' personal information for the purposes outlined in this policy or in connection with our relationship with Users:
2.1 Access to Our Website
2.1.1 When Users access our website, we automatically collect certain information and store it in log files. This information may include:
(1) Device Information. This includes the Internet Protocol (IP) address assigned to the computer connecting to the Internet, the website address and the country/region from which the User accessed our site, the requested files, browser type and version, browser plugin type and version, operating system, and platform. We use this personal information to manage our website, assess the efficiency of our systems, and analyze the geographical distribution of Users accessing our pages.
(2) Operational Information (e.g., User interactions on the page). This information might include the websites visited before and after accessing ours (timestamps related to User activity), duration of stay, time spent on particular webpages, interaction records (e.g., scrolling, clicking, and mouse hovering), browsing patterns, traffic data, network logs, and other information related to requests or downloads.
(3) Location Information. When Users enable device location features and utilize our location-based services, we may collect and process information about their actual location to provide services without requiring manual entry of geographic coordinates. Users can stop the collection of geographic location data by disabling location services, though this may prevent access to relevant services or functionalities.
2.1.2 We utilize users' personal information to enhance and maintain our website, assess user visitation, and generate reports or compile statistics that help us understand the types of users accessing our site. This information enables us to design a more intuitive user experience. We will anonymize this personal data to the greatest extent possible to ensure that individual users cannot be identified.
2.1.3 Our use of Cookies and similar technologies
(1) Some pages on our website may use Cookies, which are small files placed on the Internet browser during User visits. Cookies typically contain identifiers, site names, and some numbers and characters, allowing the website to store User preferences and other data.
(2) We will not use Cookies for any purposes beyond those described in this policy. Users can manage or delete Cookies according to their preferences; for details, please visit aboutcookies.org. Users can delete all Cookies saved on their computers, and most web browsers have features to block Cookies, but doing so will require Users to change their settings each time they visit our site.
(3) In addition to Cookies, we may use web beacons and pixel tags on our site. For example, emails we send to Users may contain clickable URLs linking to our website content. If Users click on such links, we will track the click to help us understand User preferences and enhance customer service. Web beacons are typically transparent images embedded in websites or emails that notify us if an email has been opened. Users can unsubscribe from our mailing list if they do not wish for their activities to be tracked in this manner.
2.2 Users as Our Customers or Partners
2.2.1 We will collect the following personal information provided by users when they utilize our services: name, work address, work email, phone number, job title, information provided by users during their communication with us, and any information related to background checks that may be conducted. We will inform Users in advance if any type of background check is required and, if applicable, how we will use their personal information.
2.2.2 We may collect, use, and store the aforementioned personal information to fulfill our contractual obligations to Users and inform them about our news.
2.3 Users as Potential Customers
2.3.1 We or our vendors may collect and use the following personal information from Users: name, work address, work email, phone number, job title, and any information provided during contact with us.
2.3.2 We may collect, use, and store the aforementioned personal information to contact Users about frozen goods transactions, warehouse management, financial services, and industrial park matters that may interest them, as well as to keep Users informed about our news.
2.4 Users as Our Suppliers and Employees of Suppliers
2.4.1 We collect and use the following personal information from Users directly or through indirect channels: name; work contact information (including mobile number, work address, delivery address, email); job title; surveillance recordings of Users entering our premises; and any other information provided by Users during communication with us.
2.4.2 We may collect, use, and store this personal information to facilitate and manage the services provided by Users and to communicate with Users regarding our future service requests.
2.5 Additional Personal Information We May Collect
2.5.1 If Users contact us, we may record calls for training, quality assurance, and administrative purposes. Where required by applicable law, we will obtain Users' prior consent or allow Users the option to opt-out of call recording.
2.5.2 If Users visit our office premises, they may need to register as visitors and provide their name, ID number, phone number, company name, vehicle license plate number, and the date and time of arrival/departure. We process the aforementioned personal information for security and health reasons, within the necessary scope to protect our premises, personnel, visitors, and confidential information from unauthorized access.
2.5.3 If Users voluntarily submit certain information to our services or website, such as responding to a User experience survey, we will collect the information provided as part of the request. We process Users' personal information for the purpose of addressing their requests and communicating with Users within the necessary scope to fulfill our contractual obligations to Users.
2.5.4 If Users register on our online recruitment page, they may provide us with their mobile number, Username, photo, or other resume-related information. We process Users' personal information to manage their accounts, address User requests, and communicate regarding the suitability of Users for our job openings.
2.5.5 If Users utilize our Wi-Fi services, they will need to provide their mobile number. We process Users' personal information for the purpose of sending verification codes.
2.5.6 We may obtain certain information from third-party social networking platforms, such as account details and nicknames (e.g., when Users log in to our WeChat official account using their WeChat credentials).
2.5.7 If Users participate in lotteries, contests, or similar promotional activities via our social media platforms, we may collect Users' card information and use the provided personal information to deliver such rewards.
2.6 Irrespective of the Nature of Users' Relationship with Us, We May Collect, Use, and Store Personal Information for the Following Reasons:
2.6.1 To process any inquiries or questions from Users regarding how we collect, store, and use their personal information or any requests regarding copies of Users' personal information that we hold. Even in the absence of a contractual relationship, we may process Users' personal information for legitimate customer service purposes.
2.6.2 For internal company reporting, business management, ensuring adequate insurance for our business, ensuring the security of company facilities, product development, and determining and implementing business efficiency activities. We may process Users' personal information for these purposes to uphold our legitimate interests.
2.6.3 To comply with any of our policies, laws, and regulations, which may include fulfilling legitimate interests that we reasonably believe are aligned with those of others and obligations that the law requires us to perform.
2.6.4 To establish, exercise, or defend our legal rights, which may include actions we reasonably believe are in accordance with our legitimate interests or those of others, as well as rights conferred by law.
2.7 We will not use Users' personal information in any manner inconsistent with the purposes outlined in Section 2. For the latest information regarding our processing of personal information, please contact us using the details provided in Section 12.
3. Legal Basis for Processing Personal Information
We process Users' personal information based on:
3.1 Fulfillment of our contractual obligations with Users (e.g., when Users or their companies lease one of our properties or engage in supplier agreements with us); or
3.2 Compliance with our legal obligations (e.g., for health and safety purposes or conducting background checks to comply with legal requirements).
3.3 In cases where neither Section 3.1 nor Section 3.2 applies, our legitimate interests or those of others necessitate the use of Users' personal information (e.g., ensuring the security of our website). Our legitimate interests include:
(1) Operating, developing, and expanding our business;
(2) Selecting suppliers with suitable skills and qualifications;
(3) Conducting marketing, market research, and business development;
(4) Providing services to customers; and
(5) Conducting internal management activities.
4. How We Share Users' Personal Information
4.1 We share Users' personal information with companies within our group for internal management purposes (e.g., corporate strategy, compliance, auditing and monitoring, research and development, and quality assurance) or for our legitimate interests.
4.2 We will share Users' personal information with the following third parties:
(1) Service providers (e.g., database hosting, platform providers, mail services, or background check providers);
(2) Property and facility management providers;
(3) Business partners, suppliers, and subcontractors;
(4) Our company's secretarial service providers; and/or
(5) Our lawyers and other professional advisors.
4.3 We will ensure that any third party with whom we share Users' personal information complies with the privacy and security obligations consistent with this policy and applicable laws. We guarantee that personal information will only be shared for legitimate, legal, necessary, specific, and clear purposes essential for providing services to Users. We will enter into confidentiality agreements or data processing agreements with third parties to ensure compliance.
4.4 We will also disclose Users' personal information to third parties based on the following purposes:
(1) Business operational and development needs aligned with our legitimate interests (as applicable);
(2) To fulfill any legal obligations, including compliance with government or law enforcement requests for national security, law enforcement, or preventing illegal activities;
(3) To enforce or apply our terms and conditions or any other agreements or to respond to any claims, to protect our rights or those of third parties, or to prevent any illegal activity;
(4) To protect our rights, the rights of our employees, our customers (including residents), or others' rights, property, or safety. This may include exchanging personal information with other organizations to prevent fraud and reduce credit risks.
4.5 We may also disclose and use anonymous aggregate reports and statistics about Users of our website or products and services for analysis, internal reporting, or reporting to our group or other third parties, as well as for marketing and promotional purposes.
5. Users' Personal Information Will Be Stored Within the Country
Personal information accessed and collected under this policy will be stored within the territory of the Hong Kong Special Administrative Region.
6. How Long We Retain Users' Personal Information
6.1 The retention period of Users' personal information depends on the purpose for which the data was collected or the time required to fulfill our legal obligations.
6.2 We confirm that the criteria for determining the retention period include:
(1) The duration of our ongoing relationship with Users and the provision of services to Users;
(2) Whether there are relevant legal requirements; and
(3) Whether retention is dependent on our legal requirements (e.g., statute of limitations, litigation, or regulatory investigations).
7. Users' Rights
7.1 In accordance with relevant laws, regulations, and standards in Hong Kong China, as well as common practices in other countries or regions, we ensure that Users can exercise the following rights regarding their personal information:
7.1.1 Right of Access. Users have the right to access their personal information that we hold.
7.1.2 Right to Rectification. If Users discover that the personal information we process about them is incorrect or outdated, Users have the right to request correction.
7.1.3 Right to Query and Copy. Users have the right to query and copy their personal information that we hold.
7.1.4 Right to Deletion. Within the scope permitted by relevant data protection laws, in specific circumstances, Users may request the clearing or deletion of their personal information.
7.1.5 Right to Restrict Processing. Users have the right to restrict the processing of their personal information in certain specific situations.
7.1.6 Right to Object to Direct Marketing. Users have the right to request that we stop using their personal information for direct marketing purposes.
7.1.7 Right to Data Portability. Users have the right to request that we provide their personal information to third-party service providers.
7.1.8 Right to Object to Processing. If we are processing Users' personal information for our or a third party's legitimate interests, Users have the right to object to such processing.
7.1.9 Right to Withdraw Consent. Users may withdraw their consent at any time (within the scope of our processing based on their consent), but the withdrawal does not affect the legality of processing based on consent prior to withdrawal.
7.1.10 Right to Challenge Automated Decision-Making. In certain business functions, we may make decisions based solely on automated decision-making mechanisms, including algorithms without human intervention. If these decisions significantly affect Users' legitimate rights, Users have the right to request that we lift such decisions, and we will provide appropriate remedies.
7.2 Responding to Users' Rights. To exercise the above rights, please contact us using the contact information provided in Section 12. Unless otherwise provided by law, we will endeavor to respond to all legitimate requests within 30 days. If we require additional information to process Users' requests or verify Users' identities, we will reach out to Users. Given the complexity and number of requests we receive, our response time may occasionally exceed 30 days.
7.3 If Users wish to deactivate their accounts or request the return or deletion of their personal information and other account-related information, please contact us using the contact information provided in Section 12.
8. How We Handle Children's Personal Information
8.1 Our website, products, and services are not directed towards children. We do not intentionally collect personal information from children unless:
(1) We have obtained consent from a parent or guardian,
(2) The data collection has entered into a separate agreement, or
(3) A child has visited us voluntarily or accidentally. We consider anyone under the age of 14 to be a child.
8.2 If a User is a parent or guardian and believes that their child has provided personal information to us without their consent, please contact us using the contact information provided in Section 12, and we will take steps to delete the child's personal information from our system.
9. How We Protect Users' Personal Information Security
9.1 The greatest risk in processing Users' personal information is the loss, theft, or alteration of such information, which could lead to unauthorized access by others who may use it fraudulently or disclose information that Users wish to keep confidential. Therefore, we take appropriate organizational, technical, and physical measures to protect the personal information we process or use from accidental or unlawful destruction, loss, alteration, unauthorized disclosure, or access. Organizational measures include implementing internal policies, employee training, and ensuring confidentiality obligations for our employees and third parties. Technical measures include network isolation and access control, multi-factor authentication, role-based permissions management, advanced endpoint protection, data loss prevention solutions, mature firewalls and intrusion detection systems, as well as continuous security operations center monitoring and response services. Physical measures include controlling physical access to our premises, monitoring, and auditing.
9.2 Users' personal information may be transmitted to us over the Internet. We will take all reasonable and feasible measures to ensure the security of personal information transmitted to us, but no transmission method is 100% secure. Upon receiving Users' personal information, we will implement strict procedures and security features to prevent unauthorized access.
9.3 In the unfortunate event of a personal information security incident, we will notify Users in a timely manner in accordance with legal and regulatory requirements regarding: the basic situation and potential impact of the security incident, the remedial measures we have taken or will take, suggestions for Users to autonomously prevent and mitigate risks, and remedies available to Users. We will promptly inform Users of the incident via email, letter, telephone, or push notification. If it is difficult to inform each personal information subject individually, we will take reasonable and effective measures to issue an announcement. Additionally, we will proactively report the handling of personal information security incidents to regulatory authorities as required.
9.4 If Users have any questions regarding the security of our website, please contact us using the contact information provided in Section 12.
10. Exceptions to the Privacy Policy
10.1 Our website may contain hyperlinks to websites not operated by us. Providing these hyperlinks is solely for Users' reference and convenience, and does not imply any endorsement of activities on such websites or any association with their operators. This policy applies only to personal information collected by us or received from our suppliers; we are not responsible for personal information collected and stored by third parties. Third-party websites have their own terms, conditions, and privacy policies, and we recommend that Users carefully read these terms, conditions, and privacy policies before viewing or submitting any personal information to such websites. We assume no responsibility or obligation regarding the content, terms, conditions, or privacy policies of such third-party websites.
10.2 Our services may contain links to other websites, applications, and services maintained by third parties. We do not take responsibility for the collection, use, and disclosure policies and practices of application providers, social media platform providers, operating system providers, wireless service providers, and smart device manufacturers. If Users disclose any personal information through third-party applications or social media pages, they should carefully read the privacy policies before disclosing.
11. Updates to This Privacy Policy
We may update our privacy policy from time to time. Any changes we make to the privacy policy in the future will be posted on this page. For significant changes, we will provide more prominent notifications (including, for certain services, sending email notifications outlining the specific changes to the privacy policy), or, where legally required and feasible, seek Users' consent to the relevant changes. We encourage Users to regularly review this privacy policy to stay informed about how we collect, process, and share their personal information.
12. How to Contact Us
If Users have any questions or complaints about our collection, use, or storage of their personal information, or if Users are dissatisfied with our handling of their rights regarding personal information, they may email us at support@yuhugroup.com.hk to contact us. We will investigate and attempt to resolve any such complaints or disputes regarding the use or disclosure of Users' personal information.
