Privacy Policy

This policy statement is issued in accordance with the Personal Data (Privacy) Ordinance – Cap. 486 of the Laws of the Hong Kong Special Administrative Region (the "Ordinance"), to provide information regarding the responsibilities and policies of Win-Sun Engineering Hardware Limited, its associated companies and affiliates (collectively, the "Company").

Where the operations of the Company are subject to privacy legislation outside of the Hong Kong Special Administrative Region, this policy shall be implemented in a manner that is feasible and consistent with such legislation.

In this policy, the term "personal data" shall have the meaning ascribed to it under the Ordinance.

The Company observes the responsibilities and requirements of the Ordinance. All personnel, management, and staff of the Company must at all times keep confidential all personal data collected, stored, transmitted, and/or used by or on behalf of the Company, and ensure such data is properly kept.

The Company ensures that all personal data collected, stored, transmitted, and/or used is handled in accordance with the responsibilities and requirements prescribed by the Ordinance.

In the event that an individual makes a lawful request to access and/or correct personal data held by the Company about themselves, the Company will provide and/or correct the aforementioned data in accordance with the timeframes and procedures stipulated by the Ordinance.

The Company may require you to provide the following personal data for the purpose of registering and managing your services (including related online services). Failure to provide such data may make it impossible to fulfill your service requests. Such data includes (but is not limited to):

a. Name;

b. Contact details, including contact person name, telephone number, or email address.

In certain circumstances, you may be required to provide specific information so that we may improve our products and services and provide you with information types tailored to your needs. In most cases, you may choose not to provide such information. However, if the relevant service is personalized, requiring you to provide all requested information, failure to do so will result in the Company being unable to provide the required service. Such data includes (but is not limited to):

a. Age;

b. Gender;

c. Salary level;

d. Educational attainment and professional skills;

e. Interests and leisure activities;

f. Family and household statistics.

The Company's web server also collects information regarding your internet connection in an anonymous format for aggregated server usage statistics, in order to enhance our services and better meet the needs and expectations of visitors to our website. Such data includes (but is not limited to):

a. Browser type and version;

b. Operating system; and

c. Internet Protocol (IP) address and/or domain name.

When you browse the Company's website, unless otherwise stated, the Company only records your visit and does not collect any personally identifiable information. Cookies used in any part of this website (if any) are not used for collecting personally identifiable information. Cookies are computer files stored in the computers of internet users to obtain configuration information and analyze the browsing habits of users. Cookies save you from the trouble of re-registering each time you visit the website and are usually used to track your preferred web topics. You have the right to choose not to accept Cookies, but doing so may result in your inability to use or activate certain functions of the Company's website.

The personal data you provide to the Company will be used for the following purposes ("Designated Purposes"):

a. Registering with the Company's website to use and/or activate certain functions of the Company's website;

b. Providing and delivering the products/services you requested, and contacting you regarding such products/services;

c. Operating the Company's business, including registering and managing the Company's website;

d. Conducting data sorting and analysis to enable the Company to better understand your characteristics and behavior, provide you with other services better suited to your needs, and assist the Company in selecting products/services you may be interested in;

e. Aggregated customer behavior analysis, and any other analysis, surveys, or research regarding any of the Company's products/services;

f. Direct marketing of the Company's products or services to you, and sending the Company's newsletters (if any);

g. Any other administration, operation, or maintenance of the Company's products/services/website; and

h. Use as required by law.

The Company will destroy personal data it holds in accordance with its internal retention policy. This policy states that:

a. Personal data will be retained until the Designated Purposes have been achieved, unless the aforementioned personal data is required to be retained under any applicable law or contractual obligation; and

b. According to the aforementioned criteria and the Company's internal procedures, personal data will be purged from the Company's electronic, manual, and other storage systems after a specific retention period.

All personal data held by the Company will be kept confidential; however, the Company may disclose such data to the following parties when necessary to achieve the Designated Purposes:

a. Any subsidiary, holding company, affiliate, or company controlled by or under common control with the Company, or an associated company;

b. Any individual or company representing the Company, or associated with the Company, to achieve the Designated Purposes;

c. Any other person or company under a duty of confidentiality to the Company, provided such person or company has a legal right to access the data;

d. Any person entitled to access such data under the Ordinance, provided they can prove their right to access the data; and

e. Disclosure to any entity pursuant to a court or government order. For example, if a court issues an order requiring the Company to provide data of certain customers, the Company will disclose the aforementioned data to the person formally appointed by the court.

Security of Personal Data

Physical records containing personal data are kept in locked storage when not in use.

Computer data is stored in computer systems and storage media with restricted access, and access to the data is strictly regulated.

Access to records and data is not permitted for anyone not formally authorized by management. Such rights are granted only on a "need-to-know" basis, depending on the individual's role and training within the Company.

The Company's records are controlled by designated data officers who are responsible for ensuring that the transfer or access of data is lawful and in compliance with the Ordinance.

The Company may produce audit logs to verify data changes and ensure data integrity.

The Company may have procedures to record breaches in order to investigate unauthorized attempts to access data.

When transmitting sensitive data collected online, the Company may use encryption technologies such as SSL.

According to the Ordinance, an individual has the right to:

a. Ascertain whether the Company holds personal data about themselves and (if so) obtain a copy of such data;

b. Request the Company to correct any inaccurate personal data about themselves for the purpose of using such data; and

c. Ascertain the Company's policies and practices regarding personal data, which generally comply with the provisions of this policy and practice.

Individuals may log in with their preset username and personal password to exercise their rights.

Upon satisfying itself as to the authenticity and validity of the access request, the Company will endeavor to comply with the request and provide a response within the timeframe stipulated by the Ordinance.

Individuals may log in with their preset username and personal password to exercise the right to correction.

Upon satisfying itself as to the authenticity and validity of the correction request, the Company will endeavor to comply with the request and provide a response within the timeframe stipulated by the Ordinance.

In accordance with the Ordinance, the Company will honor an individual's request not to use their personal data for direct marketing purposes. Without your consent or indication of no objection, the Company will not use your personal data for direct marketing, or provide it to others for direct marketing. Even if you have indicated your consent, you still have the right to opt-out of receiving direct marketing materials at any time. If you wish to opt-in or opt-out of receiving direct marketing materials from the Company, please email 5metalnet@gmail.com, or opt-out via the link in the Company's newsletter. You may also change your email address for receiving direct marketing materials.

Any inquiries regarding the Company’s compliance with its obligations under the Ordinance should be addressed to:

Shop A, G/F, 552 Castle Peak Road, Lai Chi Kok, Kowloon

Or by email to:
5metalnet@gmail.com