This Privacy Policy explains how Naiyide International Group Holdings Limited collects, uses, stores and discloses personal information in the course of running a holding company administration and trade desk. The policy is issued by Naiyide Group, the developer and operator of this website, on behalf of the company named above.
Our office is at 12/F San Toi Bldg, 137-139 Connaught Rd C, Sheung Wan, Hong Kong - 999077, Hong Kong (HK). You may reach the desk about any privacy matter by email at care@naiyidegroup.hair or by telephone on +17408677413.
We have written this policy in plain English so that a supplier, a carrier, a director or a visitor can understand what happens to personal information without legal training. Where the policy says we, it means the company. Where it says you, it means the person whose information we hold.
1. Scope of this Policy
This policy covers personal information that we collect through this website and personal information that we collect in the ordinary course of the desk work described on our Services page. That work includes supplier correspondence, sample consignment records, filing calendars, trade document reviews, warehouse booking records and annual return preparations.
The policy does not cover information that we hold about companies and other legal entities in their own right, such as company registration particulars, share capital figures or statutory filings that are already public. It does cover information about the individuals who act for those entities, such as directors, officers, clerks, drivers and contact persons.
The policy does not cover information collected by other organisations. If you follow a link from this website to another site, the privacy policy of that site applies to what happens there, and we are not responsible for it.
2. Who We Are
Naiyide International Group Holdings Limited is a holding company that administers a group of trading entities and runs a trade desk from its shopside office in Sheung Wan. The company is the controller of the personal information described in this policy, which means it decides why the information is collected and how it is used.
The website is developed and operated by Naiyide Group. Where this policy uses the word operator, it refers to Naiyide Group acting on behalf of the company for the limited purpose of maintaining this website.
Our registered office and business address is 12/F San Toi Bldg, 137-139 Connaught Rd C, Sheung Wan, Hong Kong - 999077, Hong Kong (HK). Correspondence about privacy may be addressed to the desk at that address, sent by email to care@naiyidegroup.hair or made by telephone on +17408677413.
3. Information We Collect
We collect only the personal information that the desk needs to answer an enquiry, carry out a service or keep a proper record. The categories below describe the information we normally hold.
Identity and contact details
This includes names, job titles, employer names, business email addresses, business telephone numbers and business postal addresses. It also includes the names of directors, company secretaries, authorised signatories and contact persons for suppliers and carriers.
Correspondence and enquiry records
This includes the content of letters, emails, forms and notes sent to the desk, the dates on which they were sent and received, and the replies we issue. Where an enquiry is made through the contact form on this website, your mail application prepares the message and no copy is stored on our servers.
Sample and consignment records
This includes lot numbers, descriptions of samples, piece counts, weights recorded on the balance stand, names of recipients and carriers, and notes about returned or altered samples. These records are kept so that a sample and its history can be traced.
Trade document particulars
This includes names, addresses and contact details that appear on invoices, packing lists, bills of lading, certificates and insurance notes, together with any comments made by clerks when a document set is checked.
Booking and access records
This includes names of carriers and drivers, vehicle particulars where a bay is booked, appointment times and the dates on which goods are held or released. Where visitors attend the office by appointment, we record the name and the time of the visit.
Website technical information
Our hosting provider may record technical information such as the internet protocol address from which a page is requested, the type of browser and the date and time of the request. This information is used to keep the website available and secure, and it is not used to identify individuals for marketing purposes.
4. How We Collect Information
We collect most personal information directly from the person concerned. You give us information when you complete the contact form, send an email, telephone the desk, visit the office or hand documents across the counter.
We also receive information from the organisations you represent. A supplier may send us a list of contact persons, a carrier may send us driver details for a booking, and a group company may send us the particulars of a new director. In those cases the organisation is responsible for ensuring that the individuals concerned understand that their details have been passed to us.
Some information is created by us in the course of the work. When a clerk writes a closing note, records a weight or marks a discrepancy in a trade document, that note or mark becomes part of our record.
We do not buy personal information from data brokers, and we do not collect information from social media profiles for the purpose of building marketing lists.
5. Why We Use Information
We use personal information for the following purposes, each of which is tied to a service that the desk actually performs.
- To reply to enquiries and to send the document lists and dates that an enquiry requires.
- To maintain supplier correspondence records so that later letters can quote earlier exchanges accurately.
- To number, weigh, shelve and trace sample lots, and to record when a sample returns or is altered.
- To maintain the group filing calendar and to contact the person responsible for a document needed before a filing date.
- To check trade document sets against orders and to return marked sets with a covering note.
- To confirm go-down bookings in writing and to reconcile booked space against actual occupancy.
- To assemble annual returns from the register, the minutes and the share records.
- To keep the register of visitors and appointments at the office.
- To keep the website available, to prevent misuse and to investigate technical faults.
- To comply with legal obligations that apply to the company and to respond to lawful requests from public authorities.
We do not use personal information for any purpose that is incompatible with the purposes listed above. If a new purpose arises, we will consider whether it is compatible with the original purpose before we use the information, and we will inform the persons concerned where the law requires it.
6. Lawful Basis for Processing
Where data protection law requires us to identify a lawful basis, we rely on one or more of the following.
Performance of a contract
We process information where it is necessary to take steps at your request before entering into a contract, or to perform a contract with you or with the organisation you represent. This covers most of the desk work, including sample handling, document checks and bookings.
Legitimate interests
We process information where it is necessary for our legitimate interests in administering the group, keeping accurate records, preventing fraud and maintaining the security of the office and the website. When we rely on this basis we consider whether your interests or rights override ours, and we limit the processing accordingly.
Legal obligation
We process information where it is necessary to comply with a legal obligation, such as maintaining company records, preparing returns or responding to a lawful request from a court or a regulator.
Consent
We rely on consent where we ask for it specifically, for example where you ask to receive occasional desk notices. You may withdraw consent at any time by writing to the desk, and withdrawal does not affect processing that took place before it.
8. Service Providers
We use a small number of service providers to keep the desk and the website running. These include the provider that hosts this website, the provider that handles our business email and, where a matter requires it, a courier or a records storage service.
Each provider is engaged under terms that require it to process personal information only on our instructions, to keep it confidential and to apply appropriate security measures. Providers are not permitted to use our information for their own marketing or to disclose it to others except as we instruct or as the law requires.
Where a provider processes information outside Hong Kong, we take the steps described in the section on international transfers below.
9. International Transfers
The desk works with suppliers, carriers and warehouse keepers in several countries, and a single matter can involve parties on more than one continent. Personal information may therefore be transferred to, stored in or accessed from a country other than the one in which it was collected.
Before making a transfer, we consider the safeguards that apply. These may include contractual terms that require the recipient to protect the information, a review of the legal environment in the destination country and, where necessary, a restriction on the categories of information that are transferred.
If you would like to know whether a particular matter involves a transfer outside Hong Kong and what safeguards apply, write to the desk and we will explain the position for that matter.
10. How Long We Keep Information
We keep personal information only for as long as it is needed for the purpose for which it was collected or for as long as the law requires.
Enquiry records
Enquiries that do not lead to work are normally kept for two years from the date of the last exchange, so that a later enquiry can be read in context. Enquiries that lead to work are kept with the matter file.
Sample and booking records
Sample lot records and go-down booking records are normally kept for six years from the close of the season, because a question about a consignment can arise long after the goods have moved.
Statutory and filing records
Registers, minutes, share records, annual returns and the working papers behind them are kept for as long as the entity exists and for the period required after it is dissolved.
Website logs
Technical logs kept by the hosting provider are normally retained for a short period sufficient to investigate faults and security incidents, after which they are deleted or anonymised.
When a retention period ends, we delete the information or, where deletion is not practicable, anonymise it so that it can no longer be linked to an individual.
11. How We Protect Information
We take the security of personal information seriously, and the measures we apply are matched to the sensitivity of the information and the way it is held.
Paper records are kept in the filing shelves behind the counter, in a room that is locked outside business hours. Access to the filing room is limited to the clerks who work there, and a file that leaves the room is signed out and signed back in.
Electronic records are held in accounts protected by strong passwords and, where available, two step verification. Access is granted by role, reviewed periodically and removed when a person leaves the desk.
Staff receive guidance on handling personal information, on recognising suspicious requests and on reporting a possible incident. A request for information that arrives by telephone is verified against the file before anything is disclosed.
No method of storage or transmission is completely secure. While we take reasonable steps to protect information, we cannot guarantee that unauthorised access will never occur, and we describe our response to an incident in a later section.
12. Your Rights
Subject to the law that applies, you have the following rights in relation to the personal information we hold about you.
- The right to be informed about how your information is used, which this policy is intended to provide.
- The right to request a copy of the information we hold about you.
- The right to ask us to correct information that is inaccurate or incomplete.
- The right to ask us to delete information where there is no good reason for us to continue to hold it.
- The right to ask us to restrict the use of information while a question about it is resolved.
- The right to object to processing that we carry out on the basis of legitimate interests.
- The right to withdraw consent where processing is based on consent.
- The right to ask for information in a portable format where the law provides for it.
These rights are not absolute. For example, we may need to keep a record to comply with a legal obligation, or we may need to keep information to establish or defend a legal claim. Where we refuse a request, we will explain the reason in writing.
13. Access and Correction Requests
To ask for a copy of your information or to ask us to correct it, write to the desk at care@naiyidegroup.hair or by post to 12/F San Toi Bldg, 137-139 Connaught Rd C, Sheung Wan, Hong Kong - 999077, Hong Kong (HK). Please describe the information you are asking about and the matter to which it relates, so that the clerk can locate the file.
We will acknowledge your request within five working days and will normally respond within thirty days. If a request is complex or involves records held in more than one place, we will tell you that the response will take longer and will give an expected date.
To protect your information, we may ask you to verify your identity before we release a copy. Where the request is made on behalf of another person, we will ask for evidence of authority to act for that person.
We do not charge for a first request. Where a request is manifestly unfounded, excessive or repetitive, we may decline it or charge a reasonable fee that reflects the administrative cost, and we will explain our decision.
15. Marketing Communications
We do not send marketing email to addresses collected through the contact form or through routine desk correspondence. If the company decides to send occasional notices to its business contacts, those notices will be limited to desk matters, will identify the company clearly and will include a simple way to stop receiving them.
You can ask us at any time to stop sending desk notices by replying to a notice or by writing to care@naiyidegroup.hair. We will action the request promptly and will keep a record that you have asked not to be contacted, so that the preference is respected in future.
16. Privacy for Children
This website and the desk work it describes are intended for businesses and their representatives. We do not knowingly collect personal information from children, and we do not direct any service to a person under the age of sixteen.
If you believe that a child has provided personal information to the desk, please write to care@naiyidegroup.hair or telephone +17408677413. We will look into the matter promptly and will delete the information where it has been provided without appropriate consent.
Where a matter legitimately involves a young person, for example a family business where a younger member acts as a contact, we collect only the details needed for the correspondence and apply the same safeguards described in this policy.
17. Third Party Websites
This website may contain links to the websites of suppliers, registries or professional bodies. Those sites are operated by other organisations, and their privacy practices are not controlled by us.
We encourage you to read the privacy policy of any website you visit before providing personal information. A link from this site does not mean that we endorse the content or the practices of the organisation that operates the linked site.
Where a third party site is used to complete a step in a desk matter, for example a registry portal used to submit a filing, the personal information you enter there is handled under that site own terms and privacy policy.
18. Automated Decisions
The desk does not make automated decisions that produce legal effects or similarly significant effects for individuals. Decisions about a matter, a booking or a filing are made by a clerk and, where required, reviewed by a second clerk.
The website uses a small amount of scripting to open the mobile navigation, to reveal sections as they scroll into view and to prepare an email message from the contact form. These functions operate in your browser and do not evaluate you or make a decision about you.
If in future we introduce a tool that automates a decision about an individual, we will update this policy and explain the logic of the tool and the way in which a person may ask for a human review.
19. Data Breach Response
If we become aware of a breach of security that affects personal information, we will act promptly to contain it, to assess its scope and to reduce the risk to the persons concerned.
Our response begins with the desk supervisor, who records the time the incident was discovered, the records affected and the steps taken to limit further loss. The supervisor then informs the responsible director and, where the incident involves an electronic system, the hosting or email provider.
Where the law requires notification, we will inform the relevant authority without undue delay and will inform the affected individuals where the breach is likely to result in a high risk to their rights. Our notice will describe what happened, what information was involved, what we have done and what steps the affected person can take.
After an incident we review what happened and change our measures where the review shows that a control was weak or missing. The review note is kept with the incident record.
20. Changes to this Policy
We review this policy at least once a year and whenever a change in our work or in the law makes a change necessary. When we update the policy we change the date at the top of the page.
Where a change materially affects the way we use personal information, we will take reasonable steps to bring it to the attention of the business contacts who deal with the desk, for example by a notice on the home page or by a short note included with routine correspondence.
The current version of the policy is always the one published on this page. We encourage you to check it from time to time if you deal with the desk regularly.
21. Complaints
If you are unhappy with the way we have handled your personal information, please write to the desk at care@naiyidegroup.hair or by post to our office address. Please describe what happened and what outcome you are seeking, and include any reference number so that the clerk can find the file.
We will acknowledge your complaint within five working days and will investigate it fairly. We will tell you what we have found and what we propose to do, normally within thirty days of receiving the complaint.
If you are not satisfied with our response, you may complain to the privacy regulator in the jurisdiction where you live or work, or in the jurisdiction where the matter arose. We will cooperate with a regulator that examines a complaint about our handling of personal information.
22. How to Contact Us
For any question about this policy, a request about your information or a complaint, use the details below.
Postal address: Naiyide International Group Holdings Limited, 12/F San Toi Bldg, 137-139 Connaught Rd C, Sheung Wan, Hong Kong - 999077, Hong Kong (HK).
Email: care@naiyidegroup.hair. Telephone: +17408677413. The desk answers the telephone during business hours, Monday to Thursday from 09:00 to 17:30 and Friday from 09:00 to 16:30, with a lunch pause from 13:00 to 14:00.
This policy is issued by Naiyide Group for the company and is maintained alongside the Terms of Service that govern the use of this website and the desk services.