3. Where the Caravel Group controls how your personal data is collected and the purposes for which we use your personal data, the Caravel Group will act as the “data controller” for the purposes of the GDPR. The Caravel Group can be contacted at 21st Floor, Central Plaza, 18 Harbour Road, Wanchai, Hong Kong.
Collection of Personal Data
4. We obtain Personal Data which you knowingly and voluntarily disclose to us, both online and offline, notably when you:
a. Visit our websites and./or complete one of our web forms;
b. Visit our premises;
c. Communicate with us via any means, including but not limited to telephone, and through use of networking websites, third party apps or similar technologies.
5. We may also collect information from third party sources such as sub-contractors.
Nature of Personal Data
6. We may use IP addresses and other anonymous data such as browser and operating system type, the time and duration of site visits and the pages visited for the purposes of:
a. obtaining aggregate information on the whereabouts of visitors to the Website; and
b. maintaining and enhancing our Website and improving our services to clients.
7. We may also aggregate any information collected via the Website (which will be annonymised so that it shall not amount to Personal Data), for such purposes as generating demographic profiles of our customer base.
9. If you have supplied it to us, we will have your personal data such as your full name and postal address, e-mail address, telephone number, job title and/or other provided personal information.
Purpose of processing
10. Any Personal Data submitted to us either in enquiries through this Website, by email or by other means provided via the Website or otherwise, will be collected, used, stored and processed by us only for the purposes of:
a. providing requested information on our products, services, pricing and processes;
b. establishing and maintaining contracts;
c. provision of contracted services;
d. invoicing, remittance, payments, collections;
e. maintaining and improving our website;
f. providing requested services to you;
g. marketing purpose;
h. IT support services;
i. business continuity planning;
j. crew recruitment or management; or
k. Employment related processing.
11. We may process your personal data for direct marketing purposes. For example, we may send you marketing communications and news concerning Caravel Group’s services, event invitations and our company newsletter.
12. We respect if you do not want your personal data to be processed for direct marketing purposes and you can always inform us about this as per the section “Contact Us” found below. As soon as you notify us, your personal data will no longer be processed for marketing purposes.
13. We process your personal data on the following legal basis:
a. It is necessary for us to comply with our legal obligations;
b. It is necessary for our legitimate interests, except where your interest and rights override those;
c. It is necessary to protect your interests or those of someone else and/or
d. In some cases, your consent
Transfer and sharing
14. We do not disclose any Personal Data given by or collected from you to any third party without your consent. However, such Personal Data may be shared with our subsidiaries, trusted associates, business partners, contractors or agents (whether inside or outside Hong Kong), IT service providers, advisors, where necessary in order to fulfil the above stated purposes, or for purposes of seeking legal or other professional advice, or to respond to a legal request, or comply with legal obligations.
15. In such cases, we require that these parties maintain your data in confidence and subject to the same restrictions as Personal Data held by ourselves, and that they use it for the specified purposes only. In order to protect the information, our servers are protected by reasonable physical and electronic security measures.
16. We may also disclose your Personal data to third parties:
a. In the event that we sell, merge or buy any business or assets, in which case we may disclose your Personal data to the prospective seller or buyer of such business or assets.
b. If Caravel Group or substantially all of its assets are acquired by a third party, in which case Personal data held by it about its customers will be transferred.
c. In the event that we are required to do so to comply with our regulatory or legal obligations, to regulatory authorities, courts, tribunals, government agencies and law enforcement agencies.
17. We also reserve the right to disclose your Personal Data to any third party if we believe that we are required to do so for any or all of the following reasons:
a. by law;
b. to comply with legal processes or governmental requests;
c. to prevent, investigate, detect or prosecute criminal offences or attacks on the technical integrity of the website or our network; and/or
d. to protect the rights, property, or safety of ourselves, the users of the website, or the public.
18. Personal data will be retained no longer than necessary pursuant to applicable law and regulation and the policies and procedures established by the Caravel Group pursuant thereto, in each case having regard to the purpose for which such personal data was obtained.
Your legal rights
19. The GDPR grants EU subject certain legal rights, a summary of which is set forth below:
a. Right of access to copy of your personal data.
b. Right to data portability.
c. Correction of erroneous data.
d. Deletion of certain data.
e. Right to object processing of personal data.
f. Right to object to direct marketing.
g. Right to restrict the processing of your personal data.
h. Right to withdraw consent.
i. Right to lodge a complaint.
20. Our Data Protection Officer – the HR Manager – can be contacted by email at firstname.lastname@example.org.
21. You may contact him if you wish to request access to, or correction or deletion of your Personal Data or withdraw your consent, or have any queries or concerns regarding this policy or its application, and we will respond within a reasonable time.