Hong Kong Cingleot Investment Management Limited (“Cingleot”, “we”, “our” or “us”) is committed to protecting the privacy, confidentiality and security of the personal data we hold by complying with the requirements of Hong Kong’s Personal Data (Privacy) Ordinance (Cap. 486).

This Privacy Policy explains what information we gather about you (“you” or “your”) when you visit this Website, what we use that information for, the purposes for which that information is used and who we give that information to. It also sets out your rights in relation to your information and who you can contact for more information or queries.

In this Privacy Policy, we refer to information which can be used, or together with other information that can be used, to identify you as your “personal data”.

• WHAT PERSONAL DATA WE COLLECT

  We collect or obtain personal data because you give it to us (for example, when you fill in the Contact Us form through our webpage of www.hksmartgateway.com (“our Website” or “this Website”)) or because it is disclosed on publicly available sources.

  The personal data that we collect through this Website include your name, your company’s name, your contact number and email address. Note that if you do not wish to or are otherwise unable to supply your personal data when completing the Contact Us form on our Website, we may not be able to respond to your enquiry, address your concern or deal with any other matters which you contact us for, where use of your personal data is required.

• USE OF PERSONAL DATA COLLECTED THROUGH OUR WEBSITE

  We use personal data collected through this Website:

  1. to manage and improve any services provided through our Website;
  2. to manage and improve our Website (including drawing up statistics on the usage of our Website);
  3. draw your attention to information about products and/or services that may be of interest to you;
  4. to manage and respond to any request you submit through our Website;
  5. to help us learn more about you, the products and services that you receive;
  6. to administer and protect our business and this Website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data); and
  7. to use data analytics to improve our Website, products/services, marketing, customer relationships and experiences.
      
• USE OF PERSONAL DATA IN DIRECT MARKETING

  We intend to use your personal data (including name, address, contact numbers and email address) in direct marketing. However, we will not do so unless you have provided us with your consent. We would like to contact you about our business and/or services, including but not limited to warehouse space, IoT smart solution, logistics service and events organised by us on the foregoing services. From time to time, we may share the above personal data with members of our Group. They may contact you with regard to their products and services.

  If at any time, you no longer wish us to use your personal data for direct marketing, please feel free to e-mail us at the addressed included in paragraph G below.

• WHO WE DISCLOSE YOUR PERSONAL DATA TO

  In connection with one or more of the purposes outlined in paragraph B above, we may share your information with the following entities:

  1. our direct and indirect subsidiaries, associated companies and affiliates of our Group;
  2. professional advisors and third parties that provide services to us (such as market research companies, printing, mailing, public relationship service providers, IT systems providers, IT support providers, customer service providers, consultants); and
  3. any competent governmental and public or judicial authorities in Hong Kong (including customs authorities, tax authorities, law enforcement agencies and any other national and/or international regulatory or enforcement body or courts or other form of tribunal).
      

  Your personal data may be accessed and processed by our personnel and the personnel of our partners, affiliates and third party service providers, who may operate within or outside of Hong Kong.

• HOW LONG DO WE KEEP YOUR PERSONAL DATA

  We will hold your personal data on our systems for as long as is necessary to fulfil the purposes for which it was collected or to comply with legal, regulatory or internal policy requirements.

• PROTECTION OF YOUR PERSONAL DATA

  We use a range of physical, electronic and managerial measures to ensure that we keep your personal data secure, accurate and up to date. These measures include:

  1. education and training to relevant staff to ensure they are aware of our privacy obligations when handling personal data;
  2. administrative and technical controls to restrict access to personal data on a ‘need to know’ basis;
  3. technological security measures, including fire walls, password protection, encryption and anti-virus software; and
  4. physical security measures, such as staff security passes to access our premises.
      

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

• YOUR RIGHTS AND HOW TO CONTACT US

  In general, and subject to certain exemptions, you have a right to:

  1. request access to your personal data from time to time;
  2. request an update or correction of your personal data; and
  3. withdraw your consent to process your personal data for direct marketing purposes.
      

  To exercise any of your rights, or if you have any other questions about our use of your personal data, please feel free to e-mail us at [email protected].

• COOKIES

  Our website uses cookies to distinguish you from other users. This helps us provide you with a good experience when browsing and also allows us to improve our site. We have a cookie policy which governs the way we use the cookies. If you disable the cookies for this Website, it may affect your using experience.

• CHANGES TO THIS PRIVACY POLICY

  This notice was last updated in 30 June 2022.

  The governing version of this Privacy Policy is the English version and shall prevail when there are inconsistencies between the English version and the Chinese version. This Privacy Policy does not extend to third-party websites that may be linked from our Website, or from any other broadcast affiliated with us.

  It may be subject to amendments. Any future changes or additions to the processing of personal data as described in this Privacy Policy affecting you will be communicated to you through an appropriate channel, depending on how we normally communicate with you.