1. Handling Your Personal Data
Keyie Company Limited (“Keyie”, “we”, “us” or “our”) is a company incorporated in Hong Kong. We respect the privacy of every individual whose personal data we handle, and we comply with the Personal Data (Privacy) Ordinance (Cap. 486) of Hong Kong (“PDPO”), including its six Data Protection Principles, and with other applicable laws.
This Privacy Policy explains how we collect, use, store, disclose and protect personal data in connection with this website, client enquiries, and our advisory, trading and procurement activities. It also serves as our Personal Information Collection Statement.
2. What “Personal Data” Means
“Personal data” has the meaning given in the PDPO: any data relating directly or indirectly to a living individual, from which it is practicable to ascertain the identity of that individual, and which is in a form in which access to or processing of the data is practicable.
3. Personal Data We Collect
Website visitors
- IP address, browser and device type, and pages viewed
- Cookies and similar technologies (see section 11)
Enquiries
- Name, organisation and email address
- Your area of interest and the content of your message
- Any further information you choose to share in correspondence with us
Prospective and existing clients
- Identity and contact details of the individuals who represent our clients
- Due diligence information where required: beneficial ownership and control of client entities, and sanctions and export-control screening results
- Bank account details for invoicing and payments
- Engagement terms, contracts, transaction and shipment records, and client communications
Suppliers and business contacts
- Name, job title, organisation and contact details of representatives of our manufacturers, logistics providers, service providers and advisers
4. Why We Use Your Personal Data
We use personal data only for purposes directly related to our business, namely:
- To respond to your enquiries and assess whether we can act for you, including conflict checks
- To carry out identity verification, due diligence, and sanctions and export-control screening, where required by law or by the nature of an engagement
- To prepare, execute and administer engagement letters, contracts and purchase orders
- To provide our advisory services, and to source, inspect, ship and clear goods for our clients
- To meet our legal, regulatory and tax obligations, and to respond to lawful requests from regulators, courts and law enforcement agencies
- To manage risk, prevent fraud and keep our systems secure
- To operate, maintain and improve this website
- With your consent only, to send you information about our services and events (see section 8)
Providing personal data to us is voluntary. However, if you do not provide the information needed for due diligence and regulatory purposes, we may be unable to respond to your request or to act for you.
We will not use your personal data for a new purpose without your prior voluntary and express consent, unless an exemption under the PDPO applies.
5. How We Collect Personal Data
We collect personal data by lawful and fair means, including:
- Directly from you, through the enquiry form on this website, by email, in meetings, and in engagement and contract documents
- From your authorised representatives or advisers
- From screening databases and publicly available sources, for due diligence purposes
- Automatically, when you use this website
6. Disclosure to Third Parties
We do not sell personal data. We may disclose personal data, on a need-to-know basis, to:
- Banks, auditors, and legal, tax and compliance advisers
- Manufacturers, inspection agents, freight forwarders, customs brokers and logistics providers, to the extent needed to carry out procurement and delivery for our clients
- Service providers that operate on our behalf, such as website hosting, form delivery, email and screening providers
- Regulators, tax and customs authorities, courts and law enforcement agencies, where required or permitted by law
- A prospective buyer or successor of our business, under a duty of confidentiality
Where we engage a data processor, we use contractual or other means to prevent the personal data from being kept longer than necessary and to protect it against unauthorised or accidental access, processing, erasure, loss or use.
7. Transfers Outside Hong Kong
Our clients, suppliers and service providers operate in several jurisdictions, including Japan and mainland China, so your personal data may be transferred to, stored in, or processed outside Hong Kong. Where this happens, we take reasonable steps, including contractual safeguards, to ensure that your personal data receives a level of protection comparable to that required under the PDPO.
8. Direct Marketing
We will not use your personal data for direct marketing, such as information about our services or events, unless you have given us your consent in accordance with Part 6A of the PDPO. We do not provide your personal data to any third party for its own direct marketing.
You may withdraw your consent at any time, free of charge, by contacting us using the details in section 14.
9. Security
We take all practicable steps to protect personal data against unauthorised or accidental access, processing, erasure, loss or use. These measures include:
- Encrypted connections (HTTPS) for this website and its forms
- Access restricted to staff and service providers who need it
- Confidentiality obligations for our staff
- Supervision of the service providers who handle personal data for us
10. How Long We Keep Personal Data
We keep personal data only for as long as necessary to fulfil the purposes for which it was collected, or as required by law. For example, contract, transaction and due diligence records are kept for as long as the law requires after a business relationship ends. Enquiries that do not lead to an engagement are deleted once they are no longer needed.
11. Cookies and Similar Technologies
This website and the platform that hosts it use cookies and similar technologies to:
- Keep the website secure and working properly
- Produce anonymous, aggregated statistics about how the website is used
We do not use advertising cookies. You can block or delete cookies in your browser settings, but some parts of the website may then not work properly.
12. Your Rights
Under the PDPO, you have the right to:
- Ask whether we hold your personal data, and request a copy of it
- Ask us to correct personal data that is inaccurate
- Withdraw your consent to direct marketing at any time
We will respond to data access and correction requests within 40 days, as required by the PDPO. We may charge a fee for complying with a data access request, which will not be excessive. If you are not satisfied with how we have handled your personal data, you may also contact the Office of the Privacy Commissioner for Personal Data, Hong Kong.
13. Changes to This Policy
We may update this Privacy Policy from time to time to reflect changes in law or in our business. The current version will always be posted on this page with its date.
14. Contact Us
Please send any questions, data access or correction requests, or requests to stop direct marketing, to our Data Protection Officer, through the form on our Contact page or by post:
Data Protection Officer
Keyie Company Limited
12F, Elite Centre, 22 Hung To Road, Kwun Tong, Kowloon, Hong Kong
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