PRIVACY POLICY

Last Updated: 11 January 2024
We reserve the right to change the terms of this Privacy Policy at any time at our sole discretion, by posting the changes on this page. YOUR CONTINUED USE OF THIS WEBSITE AND OUR SERVICES FOLLOWING OUR POSTING OF A CHANGE OF NOTICE WILL CONSTITUTE YOUR BINDING ACCEPTANCE OF THOSE CHANGES.

  1. We are committed to safeguarding the privacy of our website visitors, our application visitors (www.guowaimai.com), or when you interact with us in any form, including our mobile applications owned and controlled by Tilgaard Hong Kong Limited.
     
  2. This privacy policy applies where we are acting as a data controller with respect to the personal data of our website visitors and service users; in other words, where we determine the purposes and means of the processing of that personal data. Hence, it governs our data collection, processing, and usage practices. It also describes your choices regarding the use, access, and correction of your personal information. By using our website and our applications, you consent to the data practices described in this privacy policy. If you do not agree with the data practices described in this privacy policy, you should not use our website or our applications.
     
  3. We may change this privacy policy from time to time. Whenever we make changes to this privacy policy, the changes are effective 30 days after we post the revised privacy policy (as indicated by revising the date at the top of our privacy policy). We encourage you to review our privacy policy whenever you access our services to stay informed about our information practices and the ways you can help protect your privacy.
     
  4. We will ask you to consent to our use of cookies in accordance with the terms of this policy when you first visit our website.
     
  5. In this policy, “we”, “us” and “our” refer to www.guowaimai.com. For more information about us, see Section 10.
 
 
  1. This section explains what categories of data we process, the sources we obtain data from, the purposes for which we process the personal data, how we share your personal data, and how we allow for third-party analytics.
     
  2. We collect the information you provide directly to us. For example, we collect information when you participate in any interactive features of our services, fill out a form, request customer support, provide any contact or identifying information, or otherwise communicate with us. The types of information we may collect include your name, email address, profile picture, phone number, postal address, credit card information, and other contact or identifying information you choose to provide. The legal basis for this processing is a legitimate interest.
     
  3. When you access or use our services, we automatically collect information about you. The legal basis for this processing is our legitimate interests, namely monitoring and improving our website and services. The information we collect is including:
    1. Log Information: We log information about your use of our services, including the type of browser you use, access times, pages viewed, your IP address, and the page you visited before navigating to our services. 
    2. Device Information: We collect information about the computer you use to access our services, including the hardware model, and operating system, and version.
    3. Location Information: We may collect information about the location of your device each time you access or use one of our mobile applications or otherwise consent to the collection of this information.
    4. Information Collected by Cookies and Other Tracking Technologies: We use various technologies to collect information, and this may include sending cookies to your computer. Cookies are small data files stored on your hard drive or in your device memory that help us to improve our services and your experience, see which areas and features of our services are popular, and count visits. We may also collect information using web beacons (also known as “tracking pixels”). Web beacons are electronic images that may be used in our services or emails and to track count visits or understand usage and campaign effectiveness.
       
  4. We may combine information from other sources (for instance, a third-party service whose application you have allowed or used to sign in) and combine that with information we gather through our services in order to give you access to the Service or to generally give you better service. Consent is the legal justification for this processing.
  5. We use information about you for a variety of purposes. The legal basis for this processing is our legitimate interests, which include monitoring and improving our website and services. The purposes are including:
     
    1. Provide, maintain, and improve our services;
    2. Provide services you request, process transactions, and send you related information;
    3. Send you technical notices, updates, security alerts, and support and administrative messages;
    4. Respond to your comments, questions, and requests and provide customer service;
    5. Communicate with you about news and information related to our service;
    6. Monitor and analyze trends, usage, and activities in connection with our services; and
    7. Personalise and improve our services.
       
  6. We may share personal information about you. The legal basis for this processing is our legitimate interests, namely monitoring and improving our website and services. The information we may share about you is as follows:
    1. With third-party vendors and other service providers who need access to your information to carry out work on our behalf, such as economics, etc.
    2. If we believe disclosure is reasonably necessary to comply with any applicable law, regulation, legal process, or governmental request;
    3. To enforce applicable user agreements or policies, including our Terms of Service; and to protect us, our users, or the public from harm or illegal activities;
    4. In connection with any merger, sale of www.guowaimai.com assets, financing or acquisition of all or a portion of our business to another company; and
    5. If we notify you through our services (or in our privacy policy) that the information you provide will be shared in a particular manner and you provide such information.
    6. We may also share aggregated or anonymized information that does not directly identify you.
    7. We may allow third parties to provide analytics services. These third parties may use cookies, web beacons, and other technologies to collect information about your use of the services and other websites, including your IP address, web browser, pages viewed, time spent on pages, links clicked, and conversion information. This information may be used by us and third parties to, among other things, analyze and track data, determine the popularity of certain content and other websites, and better understand your online activity. The legal basis for this processing is our legitimate interests, namely monitoring and improving our website and services.
  1. We may provide your personal data to other members of our group of companies if it’s reasonably necessary.
  2. We may provide your personal data to our professional advisers for the purpose of obtaining advice etc. if it’s reasonably necessary.
  3. We may provide your personal data to our service suppliers and subcontractors if it’s reasonably necessary.
  4. We may provide your personal data to be handled by our payment services providers for the purpose of processing your payment.
  5. We may publicly disclose aggregated user statistics and other non-personal information.
  1. Our office and employees are physically located in Hong Kong and Denmark. According to the European Commission, the free movement of data is not restricted or prohibited within the EU/EEA.
  2. Hosting of our website and application services are located in European countries. According to the European Commission, the free movement of data is not restricted or prohibited within the EU/EEA.
  3. Our subcontractors and third-party service providers are located in the following countries, for which, according to the European Commission, an “adequacy decision” has been made with respect to this country, and transfers of data to this country will be protected by appropriate safeguards.:
  1. United States of America
  2. EU Countries
  3. Hong Kong, China
  4. People’s Republic of China
  1. We will not keep personal data for longer than necessary for the purposes that we are storing the data.
  2. The personal data that we store to fulfill our obligations and services to visitors of our website will be retained for a minimum of one month and a maximum of 24 months. This includes the data that our visitors provide us with through signup forms, registration forms, contact forms, and messages via email, phone, or other means of communication.
  3. The personal data that we store to fulfill our obligations to users of our applications will be retained for as long as determined necessary. We will deem it necessary to retain the data if the data is necessary for us to store to be able to provide and deliver the services that our users expect of us.
  4. However the provisions in section 5 we will once ever 6 months evaluate the need to store and retain the personal data that we have.
  5. If we have retained personal data for more than 24 months and the personal data has not been used in any way or is not deemed necessary to keep in any way we will delete the data.
  1. We take reasonable measures to help protect personal information from loss, theft, misuse, and unauthorized access, disclosure, alteration, and destruction.
  2. We subject personal data to pseudonymization and encryption
  3. We ensure ongoing confidentiality, integrity, availability, and resilience of processing systems and services
  4. We ensure the ability to restore the availability and access to personal data in a timely manner in the event of a physical or technical incident
  5. We have a process for regularly testing, assessing, and evaluating the effectiveness of technical and organizational measures for ensuring the security of the processing
  6. We ensure that our databases are only accessible via encryption keys and we have measures and will e.g. revoke all credentials in case of a security breach. Further, all credentials are routinely revoked and re-issued for security purposes.
  1. Most web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove or reject browser cookies. Please note that if you choose to remove or reject cookies, this could affect the availability and functionality of our services.
     
  2. Cookies do not typically contain information that specifically identifies a user personally, but it can store personal information about you and that information can be linked to any other information that is stored about you if the information is contained from cookies.
     
  3. We use cookies in the following instances:
  1. To identify you as a visitor on our website with the purpose of providing you with relevant information.
  2. To determine if you are logged into our application with the purpose of providing our services to you through our application.
  3. In security instances where cookies can help us determine if there is fraudulent use of login credentials and to protect our website and services provided through our applications.
  4. To identify you as a user that has previously interacted with us online and has opted-in to receive promotional communication from us with the purpose of providing you with relevant and necessary information.
  5. To analyze the use and performance of our website and applications with the purpose of being able to provide the best possible experience to our visitors and our users.
  6. To store the consent given to us from visitors and users of our website and applications with the purpose of providing you with the service and functionality that you request from us as a visitor or user.
  1. If you sign-up on our website to hear more about our services we will ensure that you have an easy-to-understand opt-in solution, where you can choose to opt-in to receive communication.
     
  2. In the opt-in form, it will be clearly described for what purpose we will use the data that you provide us with.
     
  3. If you opt-in to receive communication from us we will make it easy for you to opt-out again by simply letting us know that you no longer wish to receive any further communication from us.
     
  4. If you choose to opt-out of receiving communication from us, and this will hinder us in providing you the service that you have requested from us, and/or paid for to us, we will let you know that we will no longer be able to provide you with our services.
     
  5. If you are a visitor of our website and have chosen to opt-in to receive promotional emails from us, you will furthermore have the opportunity to opt-out of receiving any promotional emails from us by following the instructions in those emails that we send you with promotional emails.
     
  6. You may instruct us not to process your personal data for any marketing purposes.

As the data subject, you have the following rights:

  1. Right of Access: You have the right to request access to the personal information we hold about you.
  1. Right to Rectification: Pursuant to data protection laws, if you discover any errors or inaccuracies in the personal information we hold about you, you have the right to request a correction.
  1. Right to Erasure: Pursuant to data protection laws, you have the right to request the deletion of your personal information held by us, unless there are legal requirements or legitimate grounds for retaining such information.
  1. Right to Restriction of Processing: Pursuant to data protection laws, you have the right to request restriction of the processing of your personal information, in certain circumstances, such as when you contest the accuracy of the information.
  1. Right to Lodge a Complaint: Pursuant to data protection laws, if you believe that our processing of your personal information violates applicable data protection laws, you have the right to lodge a complaint with the supervisory authority.
  1. Right to Data Portability: Pursuant to data protection laws, where applicable, you have the right to request that we provide your personal information in a structured, commonly used, and machine-readable format, so that you can transmit it to another data controller.
  1. Right to Object: Pursuant to data protection laws, if we process your personal information based on legitimate interests, you have the right to object in certain circumstances, and we will cease processing your personal information unless we have compelling legitimate grounds to continue.

If you wish to exercise any of the above rights, please refer to the following links for detailed information on the relevant provisions:

– Right of Access: https://gdpr-info.eu/art-15-gdpr/

– Right to Rectification: https://gdpr-info.eu/art-16-gdpr/

– Right to Erasure: https://gdpr-info.eu/art-17-gdpr/

– Right to Restriction of Processing: https://gdpr-info.eu/art-18-gdpr/

– Right to Lodge a Complaint: https://gdpr-info.eu/art-19-gdpr/

– Right to Data Portability: https://gdpr-info.eu/art-20-gdpr/

– Right to Object: https://gdpr-info.eu/art-21-gdpr/

  1. Our website and applications are owned and operated by Tilgaard Hong Kong Limited.
  2. Our company is registered with the authorities in Hong Kong, China with the registration number 1282121.
  3. Our company is physically located at Rm 909b, 9/f., Two Grand Tower, 625 Nathan Road, KLN, Hong Kong, China. 
  4. You can contact us in the following ways:
    (1) By post to our address, as described in 10.3.
    (2) By using our signup, contact, or registration form on our website.
    (3) By email at sales@guowaimai.com
    (4) Go to www.tilgaard.com

Last Updated: 11 January 2024
We reserve the right to change the terms of this Privacy Policy at any time at our sole discretion, by posting the changes on this page. YOUR CONTINUED USE OF THIS WEBSITE AND OUR SERVICES FOLLOWING OUR POSTING OF A CHANGE OF NOTICE WILL CONSTITUTE YOUR BINDING ACCEPTANCE OF THOSE CHANGES.