Privacy Notice for Wallem Websites and Internet Services
Wallem Group, including its affiliates, is committed to protect and respect your privacy in compliance with applicable data protection and privacy laws. It is our commitment that personal data will be collected and used only for the purposes for which it was originally submitted or in accordance with your preferences.
The purpose of this Privacy Notice is to explain why we collect personal data, how we use it, when would we share it with third parties, how we keep it and your rights about protection of your privacy. This Privacy Notice applies to the use of Wallem’s websites (individually called “Website”), including your subscription of any services via our Website(s) and when you are leaving any information (e.g. message) at our Website.
We reserve the right to update this Privacy Notice so to ensure our compliance with the applicable data protection and privacy laws. Please review this Privacy Notice from time to time for any amendments.
We have appointed a data protection team which is responsible for overseeing questions in relation to this Privacy Notice. If you have any questions regarding this Privacy Notice or the use of your personal data, please contact the data protection team using the details set out below:
Full legal entity name: Wallem Group Limited
Postal address: 9/F Dorset House, Taikoo Place, 979 King’s Road, Quarry Bay Hong Kong
Data Protection Team email: email@example.com
Data Protection Officer:
Mrs Agnes Poon
Phone: +852 2876 8042
The data we collect about you
Personal data, or personal information, means any information about an individual from which that person can be identified.
We shall collect from you the personal data relevant and necessary for conducting the type of Activity (defined below) you requested. Further, information about your usage of the Website shall be collected using cookies. Before collecting these personal data and information, we would explain to you the purpose of collecting them and obtain your consent.
Data provided by you
In connection with registration to our services, the circumstances in which you may need to provide us personal data include: inquiries, subscriptions, surveys and responding to your other requests (generally referred to as “Activity”). , We will only collect relevant personal data (to the extent and type(s) necessary) for the purpose of conducting the Activity, for examples:
- Contact details (e.g. name, address, telephone number, email address, city of residence and country of origin)
- Username in relation to online services
- Possible feedback and inquiries and messages provided by you
- Marketing data which includes your preference in receiving marketing materials and information from us, for example subscription or opting in from receiving any marketing message from us
- Relevant information for supporting your requests and/or applications
- Any other information that may be provided by you personally to Wallem Group
Observed data about your online usage
When visiting the Website, observed data about your online usage would be collected. The data is collected using cookies and other similar technologies. Such data may include:
- Webpages visited by the user
- Other websites the user accessed via our Website(s)
- The device model
- The channel through which the service is accessed (web browser, mobile browser, application, etc.)
- Browser version
- Operating System
- IP address
- Session identifier
- Session time and duration
- Geographical location data
- Date and time
- Screen resolution
- Clicks, scrolling, etc.
Purpose of processing
The purpose of processing your personal data is to:
- Communicate between us and you and reply to your contact requests, inquiries and feedback
- Ensure an efficient and secure use of our Websites and services
- Improve our Websites and website user experience
- Provide customized services and content recognizing your specific needs and interests
- Enable access to your user accounts
- Provide marketing information for Wallem solutions and services via the means dedicated by you (e.g. targeted e-mails or interpersonal communication)
- To manage our customer relationships which may include asking you to leave a review or to take survey
- Conduct research and collect statistics (e.g. what sections of our Websites the users visit and how much time they spend on the Websites)
- To use data analytics to improve our solutions and services and customer experience
- To process your application for a job in Wallem Group when you apply it through our job vacancies page (including to conduct background checks and employer references)
- To satisfy legal obligations which are binding on us
- For the establishment, defence and/or enforcement of legal claims
Legal basis for processing your personal data:
- Fulfilling contractual relations between you and Wallem Group (e.g. contacting you in relation to subscriptions and registrations)
- Legitimate interest of Wallem Group (observing your website usage in order to ensure an efficient and secure use of our Websites, to develop our services, to provide customised content to make our services more relevant to you, to comply with any court order or to prevent fraud or other crime, to correspond with you for any enquiry or message you have left on or via our Website(s) and to collect statistics)
- Your consent - your consent will be asked in relation to using website cookies, processing your personal data other than for the purpose originally collected and contacting or providing you commercial or marketing information. You will find additional information on how cookies are used in this Privacy Notice.
Marketing and opting out
You will receive marketing communications from us if you have requested information from us. You can ask us to stop sending you marketing messages at any time by following the opt-out links on any marketing messages sent to you or by contacting us at any time.
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a solution or service purchased, and will not affect continuous business relations, etc.
Storing personal data
We handle your personal data that you have provided to us separately from observed data about online service use (for example, details you provided to us when subscribing to the online Wallem magazine) and derived data, in separate databases. Observed or derived data about service usage is always stored in a way that users cannot be personally identified from the identifiers as the identifiers are generated randomly.
Your personal data is stored as long as necessary in relation to the purposes for which the personal data was collected, unless there is a legal obligation to retain the personal data longer (e.g. in case of an ongoing legal proceeding).
If you object to further contact from us, we will keep some basic information about you in order to avoid sending you unwanted communications in the future. We will confidentially dispose of or permanently delete your personal data if (i) your personal data is no longer necessary for the Activity, (ii) we are no longer lawfully entitled to process it or (iii) you validly exercise your right of erasure.
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. In addition, we authorize access to your personal data to those employees, agents and contractors and other third parties who have a business need to know (for example, Marketing department will utilize your data to send out marketing materials you opted in to receive). They will only process your personal data on our instructions, and they are subject to duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
Wallem Group uses the services of Google Analytics, a web analytics service provided by Google Inc. Data collected by cookies about your use of our Websites, solutions and services, including your IP address, will be transmitted to and stored by Google on behalf of Wallem Group. Wallem Group uses such analytics services for the purpose of evaluating website performance, usage, and providing other services relating to website activities and internet usage.
According to Google, they will in no event connect your IP address with other of Google’s data.
To prevent your data from being used by Google Analytics, you can opt out by following the instructions provided here https://tools.google.com/dlpage/gaoptout
Our Websites may contain links to other websites and ‘share’ and/or ‘like’ buttons, such as Twitter, Facebook, and other social media platforms, that are not operating on Wallem Group’s behalf. Such websites, service or application providers may place their own third-party cookies on users’ computers and other devices, collect data, or solicit personal information.
Issuers of such third-party cookies have their own privacy policies. You should refer to any privacy policies from such websites, service or application providers to better understand how your information may be collected and used.
We use the following cookies on our Websites:
These cookies record your visit to our Websites, the pages you have visited and the links you have followed. We will use this information to make our Websites and the content displayed on it more relevant to your interests.
If you have a professional relationship with us or have given your consent to receive marketing messages from Wallem Group, we may use your e-mail address to send you electronic marketing information.
How do you disable cookies?
Please note that if you have consented to the usage of cookies, you can withdraw your consent at any time by clearing your browser’s data. Read more about clearing your browser’s data here.
Disclosure and transfer of personal data
At Wallem we handle your personal data only according to the defined purposes of processing.
Personal data can be disclosed to the following third parties:
- Internal third parties – legal entities in the Wallem Group
- External third parties – legal entities outside the Wallem Group including but not limited to service providers acting as processors who provide operational support, providers of web analytics services, providers of marketing automation services, providers of outsourced IT and document storage providers; consultants and other service providers to enable the performance of services for us.
In some cases, the recipients of personal data may be located outside of EU/EEA, in which case we will ensure that sufficient level of data protection is maintained through appropriate safety measures, e.g. by using EU commission’s standard contractual model clauses.
Under certain circumstances, you have the following rights:
- the right to check what kind of personal data has been collected about you and how we use your information;
- the right to have your information rectified, erased or place restrictions on processing your data;
- the right to restrict the processing of your personal data or when the processing is based on our legitimate interests, to object the processing on grounds relating to your particular situation;
- the right to request your personal data to be provided in a structured, commonly used and machine-readable format and your personal data to be transferred to another data controller, when technically feasible;
- the right to withdraw your consent given to us for the processing of your personal data at any time;
- the right to object to the processing of your personal data at any time;
- the right to prevent your information from being used for direct marketing purposes. You can opt out from receiving marketing materials from us at any time;
- the right to lodge a complaint with a competent supervisory authority, if you consider that the processing of your personal data infringes any applicable data protection and privacy law. Wallem has nominated Die Hamburgische Datenschutzbeauftrage as our lead supervisory authority.
We would however appreciate the chance to deal with your concern before you approach them, so please contact us in the first instance.
If you have any questions regarding this Privacy Notice or the use of your personal data in Wallem, please contact us at firstname.lastname@example.org