1. The Caravel Group Limited and its subsidiaries, affiliates and associated companies, are hereinafter called “the Caravel Group”. The Caravel Group is headquartered at 21st Floor, Central Plaza, 18 Harbour Road, Wanchai, Hong Kong.
4. 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.
Collection of Personal Data
5. 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.
6. We may also collect information from third party sources such as sub-contractors, business partners.
Nature of Personal Data
7. 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.
8. We may also aggregate any information collected via the Website (which will be anonymised so that it shall not amount to Personal Data), for such purposes as generating demographic profiles of our customer base.
10. We may process your contact information such as your full name and postal address, e-mail address, telephone number, job title and/or other provided personal information.
Purpose of processing
11. 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. to verify your identity in order to comply with anti-terrorist financing and anti-money laundering regulations.; or
k. Employment related processing.
12. 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.
13. 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.
14. 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
Storage, transfer and sharing
15. The personal data collected by the Caravel Group will be stored and processed in Hong Kong or in a country in which we or our affiliated entities or associated third parties maintain facilities. In order to protect the information, Caravel Groups servers are protected by reasonable physical and electronic security measures.
16. 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. In case we need to transfer your personal data, we will take all reasonable measures to safeguard the transfer of your personal data to third parties in a manner that complies with the applicable data protection laws.
17. 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.
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:
- Right to be informed
- Right of access: right to request a copy of the information the organisation holds
- Right of rectification: individuals have the right to correct data that is inaccurate or incomplete.
- Right to be forgotten: in certain circumstances, individuals can ask the organisation to erase any personal data that’s stored on them.
- Right of portability
- Right to restrict processing: individuals can request that an organisation limits the way it uses personal data.
- Right to object: individuals have the right to challenge certain types of processing, such as direct marketing.
- Rights related to automated decision-making including profiling
- Right to withdraw consent
20. If you have any questions on how we collect and treat personal data or would like to exercise any of the abovementioned rights, please send your inquiries to: email@example.com
22. We may change this policy from time to time. We will also post an updated copy of the policy on our website, please check it for updates.
23. All matters relating to this website are governed by the laws of Hong Kong.