Data Privacy & Security Policy
The information that you provide is collected to help us to improve the services we offer, enable us to provide services tailored to individual users' requirements.
We are committed to protecting your privacy
Newhaven Group and its affiliated companies ('Newhaven') has a strong commitment to protecting the privacy of our clients and staff.
To ensure you can make informed decisions and feel confident about supplying your personal data to Newhaven we provide this policy statement outlining our data collection practices and the choices you have concerning how the data is being collected and used.
The term 'Data' refers to any personal information that can be used to identify you as an individual. It can include, among other things, your name, contact number, address, age, gender, your ID card number, passport or other identification document details, driver’s licence details or personal financial information.
We limit the collection, use and retention of Data to the specific information we need for legitimate purposes to administer our business, including employment of staff, providing quality professional services to existing and potential clients and offering various products or services that may be of interest to you. We take appropriate steps to protect Data collected against unauthorised access, disclosure or alteration, and to keep such Data accurate and up to date.
This privacy statement contains numerous general and technical details about the steps we take to respect your privacy concerns. We have organised the privacy statement by major processes and areas so that you can review the information of most interest to you.
Please read this policy statement carefully before submitting any Data to us. If, after reviewing this privacy statement you have any privacy questions or concerns or would like to request access to, correction or object to the processing of your Data for legitimate purposes, please email email@example.com or firstname.lastname@example.org for the rest of the world. Visitors in Hong Kong can also send a letter or fax to:
Data Privacy Officer, Newhaven (Hong Kong) Limited, 1906/7, 19/F, FWD Financial Centr 308 Des Voeux Road Central Hong Kong Fax: +852 2115 9297
Please allow 10 business days for us to process any request for access to or correction of Data.
In order to protect your Data, we will require that you prove your identity to us in relation to your request to access your Data, which may consist of a copy of a government-issued identification, your signature and correspondence address so we can check them against our records and satisfy ourselves as to your identity. The above information is required to create an audit trail of how the request has been handled. Where a request is made, any correspondence or application may be kept and added to your Data.
This data privacy statement was written on 30 September 2014. In the future, we may need to make additional changes. All additional changes will be included in the latest data privacy statement published on our website, so that you will always understand our current practices with respect to the information we gather, how we might use that information and disclosures of that information to third parties. Any changes to our statement will become effective upon posting of the revised statement on our website. We will seek your express consent to any changes to how we use or disclose your Data if requested by law but otherwise use of our website and/or our services following such changes will constitute your acceptance of the revised statement then in effect.
Why we collect Data and how we use it
When you seek employment with Newhaven, request a particular service from us or otherwise interact with Newhaven, we will ask you to voluntarily provide us with Data that we need. For example, if you request services, pursuant to required due diligence and know your client processes, we will request Data such as your name, proof of residential address, government issued identification document, telephone number, e-mail address, bank account etc. information for processing and record purposes.
When you browse our website, we do not collect Data unless you voluntarily and knowingly provide it to us, for example by accessing our website from a link in an e-mail that we send to you, or requesting a newsletter.
Third Party Providers
This policy statement does not apply to our processing of Data on behalf of, or at the direction of, third party providers who may collect Data from you and provide it to us. In this situation, we would merely act as a data processor and thus advise you to review applicable third party providers’ privacy policies before submitting Data.
How we store and transmit Data
We have policies and procedures to limit access to Data to authorised personnel only.
We store Data in secure databases located on dedicated servers which reside behind firewalls to protect the Data from unauthorised or accidental access.
Newhaven maintains a database of information which is used for marketing, promotion and research to promote and to improve our services. You will only receive marketing and promotional materials if you have opted-in or given permission for Newhaven to send you such materials. You may elect to unsubscribe from receiving future e-mail promotions at any time.
Secure transmission and storage of Data
We treat all Data that you provide to us as confidential information. To prevent Data from unauthorised access or leakage, we have adopted and regularly monitor our security and data privacy policies and procedures.
Disclosure of information to third parties
We use the services of third party agents, including e-mail and technology service providers. These parties are contractually prohibited from using Data for any purpose other than for the purpose specified in their respective contracts. We do provide non-personally identifiable information to certain service providers for their use on an aggregated basis for the purpose of performing their contractual obligations to us. We do not permit the sale of Data to entities outside of Newhaven or any use unrelated to our group operations or use of Data by third party for their own purposes. Newhaven will implement, where necessary appropriate measures, including contractual clauses, to secure the transfer of your Data to the third party service providers located in a country with a level of protection different from that of Hong Kong or other jurisdictions we oprate in.
E-mails about special offers, promotions and opt-out
It is our intention to only send you mail and e-mail communications that will be useful to you and that you may want to receive. If you indicate that you would like to receive promotional material in response to a request from us for such a confirmation and you provide your e-mail address to us in order to receive marketing communications, we will periodically contact you via e-mail and provide information about special offers and promotions that may be of interest to you. These communications will relate to offers relating to Newhaven. We may use third party e-mail service providers to send e-mails. These service providers are contractually prohibited from using your e-mail address for any purpose other than to send e-mails related to our group operations. Data will not be shared with third parties for their own marketing purposes.
We will provide you with the ability to unsubscribe from all marketing communications. Every time you receive an e-mail, you will be provided with the choice to opt-out of future e-mails by following the instructions provided in the e-mail. You may also opt-out of receiving promotional materials by sending an email to email@example.com or firstname.lastname@example.org or a letter or fax to:
Data Privacy Officer Newhaven (Hong Kong) Limite 1906/7, 19/F, FWD Financial Centre 308 Des Voeux Road Central Hong Kong Fax: +852 2115 929
Please allow 10 business days for us to process your opt-out.
How long will Data be retained?
Data will be stored by Newhaven for as long as required for the business purpose for which the Data is processed and thereafter will be kept for the period of time required or permitted by law. However, information that is stored on Newhaven servers may be edited or deleted by users of such service at any time.
Notifications in the event of breach
In the unlikely event of a Data breach, we shall follow any laws and regulations which would require us to notify you of the disclosure of private information.
This privacy statement is pursuant to the Personal Data (Privacy) Ordinance of the Hong Kong Special Administrative Region and applicable local laws.