1. The introduction.
This Privacy Policy (the “Policy”) establishes the rules under which the personal data of the users and visitors of the https://controlexltd.com (the “Website”) are processed. The Website is owned and operated by CONTROLEX LIMITED, the company incorporated in Hong Kong, under the Company Number 2645205, with its registered address at 8F, 30 Hollywood Road, Central, Hong Kong (the “Company”, “we”, “us”, “our”). E-mail address of Company`s DPO (data protection officer) is dpo@controlexltd.com. We are the “data user” in the meaning of the Personal Data (Privacy) Ordinance.
For other questions (that are not related to this policy), please, do not hesitate to contact us via e-mail address info@controlexltd.com.
2. Personal data collection.
Log Data.
When you use the Website, the following data are collected automatically. These include the following:
- Your user agent string (type and version of your browser and the languages supported by your browser, type and version of the installed operating system, the information about your electronic device);
- System configuration information and other information about the traffic to and from the Website;
- You IP address.
Message data.
When you send a message to the Company via available contact details, you hereby provide the Company with the following data:
- Your full name;
- Your phone number;
- Your e-mail address;
- Information about the company you work for (if applicable);
- Your message.
Order data.
When you order any Resources from the Website, you hereby, in addition to the message data, provide us with the data about your order.
Marketing data.
We also collect information on whether have you consented to include your e-mail address to our mailing list.
Verification data.
In case if required by applicable Law and/or Ordinance you may be asked to pass the Verification. In this case, the following data must be provided by you:
- Copies of documents and photos required to pass the Verification.
Financial data.
In some cases, we may receive the information about the payments you have made for the Resources of the Website.
3. A description of the purpose or purposes for which the personal data referred to in provision “2. Personal data collection.” are collected, held, processed or used by the Company.
We may use the personal data referred to in provision “2. Personal data collection.” for the following purposes:
To administer, protect and enhance this Website.
We use your personal data (particularly, log data) for the following purposes:
- Protect this Website from any cyberattacks and digital threats. This includes DDoS attack and other relevant attacks;
- Prevent violation of our Terms and Conditions, applicable Ordinances and Laws by you or anyone who uses your device to access the Website;
- Analyse the usage of the Website by the visitors/users and, with the help of this information, develop this Website by adding new functions, features, and developing existent ones;
- Diagnose any problem with the Website and a Server, that makes the Website available.
To comply with applicable legislation.
Some kinds of the data concerning you (including, but not limited to, order data, financial data, verification data) for the purposes of compliance with applicable legislation. These includes, without limitation, Personal Data (Privacy) Ordinance and Anti-Money Laundering and Counter-Terrorist Financing Ordinance. This purpose includes giving replies to the legal requests of the data subjects.
To send you news about the Company.
If you have consented to inclusion your e-mail into our mailing list, your marketing data will be used the purpose of sending you our newsletter.
To contact you.
We may use your communication data in order to contact you for various purposes. For example, when replying to your feedback, questions and other messages.
To provide you with our Resources.
We may use your order data to provide you with our Resources. Additionally, we may also use your financial data to verify that you have paid for the Resources.
To conduct independent revisions and audit.
In some cases, the Company may pass an audit or revision by third-party. In this case, your data may be used for this purpose.
4. Persons to whom the Company discloses, intends to disclose or may disclose the personal data referred to provision “2. Personal data collection.”.
Here you can find the classes of persons to whom the Company discloses, intends to disclose or may disclose the personal data referred to provision “2. Personal data collection.”
Employees of the Company.
Our Company is maintained and operated by many persons, who may have access to your personal data. Examples include, but not limited to, Data Protection Officer, Financial Department, Support Department, Legal Department, and other ones. These persons will have an access to your data in strict confidentiality – this is achieved by signing proper confidentiality agreements.
Subcontractors and Affiliates of the Company.
Some facilities and capacities of the Company belong to the legal persons, other than the Company. Thus, in some cases, your personal data may be disclosed to them.
Third-party Contractors.
These includes, but not limited, independent contractors, auditors. This disclosure will be made in case of a third-party audit.
Governmental organisations.
Your personal data may be disclosed to the governmental organisations of our Hong Kong or other jurisdiction in case of this disclosure is required by the Laws of Hong Kong.
Host providers.
The Server, that makes Website available, may belong to a third party. Thus, your personal data may be disclosed to this person. Please note, that the data will be transferred only in encrypted form, that makes impossible to decrypt those data without decryption keys.
Google Inc.
We use the Google Analytics Services, supplied by Google LLC., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. Google Analytics uses so-called “cookies”. The information generated by the cookie about your use of the Website is usually transmitted to a Google server in the USA and stored there. Google Analytics Opt-out Browser Add-on provides visitors and users with the ability to prevent their data from being collected and used by Google Analytics. To install Google Analytics Opt-out Browser Add-on, follow this link: https://tools.google.com/dlpage/gaoptout?hl=en. In addition, the Company use Google reCAPTCHA. reCAPTCHA protects the Website from spam and abuse. This tool is primarily used to distinguish whether an input is made by a person or abusive by automated processing. To find out more about processing of the data by Google, please, follow Google`s Privacy Policy https://policies.google.com/privacy.
Cloudflare Inc.
The Company use the Services, provided by Cloudflare, Inc. 101 Townsend St, San Francisco, CA 94107 USA. Сloudflare provides web optimization and security services that the Company uses to improve and protect the Website, including a reverse proxy, pass-through security service. Cloudflare may collect the following data concerning you: IP address, system configuration information and other information about the traffic to and from the Website (previously mentioned “log data”). Cloudflare uses these data in order to detect new threats, identify malicious third parties, and provide security protection to the Website. Additionally, the Company uses a cookie, provided by Cloudflare (to find out more, please, follow Cookie Policy). To find out more about processing of the personal data by Cloudflare, please follow https://www.cloudflare.com/privacypolicy/ or https://www.cloudflare.com/privacypolicy/10.31.19/.
5. Protection of minors.
Website is not directed to the persons under the age of 18. If you are a parent and believe that your child under the age of 18 has used the Website and provided his/her personal data to us through the Website, please, contact the Company via contact details in order to request us for the removal of the personal data of your child.
6. Your data subject`s requests.
In accordance with Personal Data (Privacy) Ordinance, you can control the processing of your personal data sending request(s) to our Data Protection Officer. E-mail address: dpo@controlexltd.com.
Data access request.
You may make a request:
- to be informed by the Company whether the Company holds personal data of which you are the data subject;
- if the Company holds such data, to be supplied by Us with a copy of such data.
Data correction request.
You may make a request for correction of your personal data if these data are inaccurate.
Refusal to comply with the request.
If the Company must refuse to comply with your request in accordance with the applicable Law and/or Ordinance, you will be notified about the refusal to comply with your request and the legal basis for this refusal.
6. Complaints information.
You can direct all your complaints and questions to our Data Protection Officer. Nevertheless, if you want to complain about the processing of your personal data by the Company, you can direct your complaints to the Privacy Commissioner for Personal Data of Hong Kong. The Website of the Privacy Commissioner www.pcpd.org.hk.
7. International data transfers.
Please note, that our Company operates globally. Thus, your data are to be collected and stored in the places outside Hong Kong. By agreeing to this Policy and by using this Website, you hereby agree to the processing of your data outside Hong Kong.
8. Changes to this Policy.
We may change, amend, correct or modify this Policy from time to time. If we do, we will let you know by revising the date of this Policy. We encourage you to review the Privacy Policy whenever you access our Website. By continuing to use our Website after Policy changes go into effect, you agree to be bound by the revised Policy.
9. Cookie Notice.
We have developed this cookie notice (the “Notice”) in order to explain how we use cookies and similar technologies (collectively, “Cookies”) on the website. This Notice is an integral part of this Policy. By agreeing to the Policy, you hereby agree to this Notice.
What are Cookies?
Cookies are small text files containing user IDs that are automatically placed on your computer or other device when you visit a website. The Cookies are stored by the internet browser. The browser sends the Cookies back to the website on each subsequent visit, allowing the website to recognise your computer or other device. This recognition enables the website provider to observe your activity on the website, deliver a personalised, responsive service and improve the website.
How can you control cookies?
You can change your cookie settings within your internet browser. Your internet browser allows you to change your cookie settings. Such browser settings for cookies are typically found in the “options”, “tools” or “preferences” menu of your internet browser. You may also consult the browser´s “help” menu. Different browsers may use different mechanisms to disable cookies.
Cookie settings for Internet Explorer.
Cookies used by the Website.
- Expiration time – one year. Reason for use: The _cfduidcookie helps Cloudflare detect malicious visitors to our Customers’ websites and minimizes blocking legitimate users. It may be placed on your device of identify individual clients behind a shared IP address and apply security settings on a per-client basis. It is necessary for supporting Cloudflare’s security features.
- Expiration time – two years. Reason for use: used to identify users.
- _gat_gtag_UA_124543993_1. Expiration time – 24 hours Reason for use: Used to throttle request rate. Cookie is deployed via Google Tag Manager.
- _gid. Expiration time – 24 hours. Reason for use: used to identify users.