PRIVACY POLICY

Thank you for visiting our website and for your interest.

This Data Privacy Policy (hereinafter referred to as the “Policy”) set forth the rules for using the website at https://hermeshaul.com/ (hereinafter referred to as the “Website”).

Moreover, this Policy aims to inform you about the processing of your personal data that we collect when you visit our Website. Our data protection practice incorporate and follow relevant provisions of the legal regulations of the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons about the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (“General Data Protection Regulation”) (text with EEA relevance) (OJ L 119 04.05.2016, p. 1, ELI: http://data.europa.eu/eli/reg/2016/679/oj) (hereinafter referred to as the “GDPR”) where appropriate and the Personal Data (Privacy) Ordinance (Cap. 486) (Originally 81 of 1995 — 80 of 1997, L.N. 362 of 1997, 4 of 1998, 25 of 1998, 34 of 1999, 12 of 2000, 47 of 2000, 5 of 2002, L.N. 106 of 2002, 23 of 2002, 18 of 2006, 20 of 2006, L.N. 130 of 2007, 1 of 2010, 18 of 2012, E.R. 1 of 2013, 18 of 2014, 12 of 2015, 17 of 2018, 32 of 2021, L.N. 66 of 2022) (https://www.elegislation.gov.hk/hk/cap486!en-zh-Hant-HK.pdf?FROMCAPINDEX=Y). 

The following data protection declaration serves to fulfil the information obligations resulting from the GDPR. These can be found, for example, in Art. 13 and Art. 14 ff. GDPR.

Hermeshaul Limited, 9/F, AMTEL BUILDING, 148 DES VOEUX ROAD CENTRAL, CENTRAL, HONG KONG, 77496737 (hereinafter referred to as the “Company”, “us”, “controller” or “we”) is the operator of this Website.

This Information on personal data processing is valid and effective from 1.02.2025.

DATA PROTECTION POLICY

    The Company, as the owner of this Website, hereby informs users that the Company is the data controller for the personal data processed on this site, unless otherwise specified with specific processing activities.

    Users are informed that their personal data will only be collected and processed for specified, explicit, and legitimate purposes, and only to the extent that it is adequate, relevant, and limited to what is necessary in relation to those purposes.

    1.1 Data Subject Rights

    Users have the right to request from the data controller access to their personal data, rectification or erasure of their data, restriction of processing, data portability, and to object to processing.

    Where processing is based on consent, users have the right to withdraw their consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal. If processing is based on a legal basis other than consent, users have the right to object to the processing. See Section 6 of this Policy for further information on data subject rights.

    1.2 Data Processing of Children’s Data

    When data concerning children is collected, processing is lawful only if consent is given or authorized by the holder of parental responsibility or guardianship over the child.

    1.3 User Responsibility for Data Accuracy

    Users are solely responsible for the accuracy, completeness, and validity of the data they provide, including ensuring that it is kept up to date.

    1.4 Security Measures 

    The Company has adopted the legally required levels of security for the protection of personal data and has installed all the technical means and measures at its disposal to prevent the loss, misuse, alteration, unauthorized access and theft of the same.

    NAME AND ADDRESS OF THE CONTROLLER 

      The controller within the meaning of Art. 4 (7) GDPR is the person who alone or jointly with others determines the purposes and means of the processing of personal data.

      With regard to our Website, the responsible person/s or department in the Company is:

      Hermeshaul Limited, Compliance Unit

      Address: 9/F, AMTEL BUILDING, 148 DES VOEUX ROAD CENTRAL, CENTRAL, HONG KONG 

      Website: https://hermeshaul.com/ 

      Email: privacy@…

      ADDRESS AND CONTACT DATA OF THE DATA PROTECTION OFFICER 

        We have appointed a data protection officer in accordance with Art. 37 of the GDPR. You can reach our data protection officer under the following contact details: 

        Hermeshaul Limited

        Address: 9/F, AMTEL BUILDING, 148 DES VOEUX ROAD CENTRAL, CENTRAL, HONG KONG 

        Website: https://hermeshaul.com/

        Email: privacy@…

        PURPOSE OF THE PROCESSING AND LEGAL BASIS

          At our Company, we process the data received through this form to manage the queries made and attend to your possible requests.

          We temporarily store your IP address to enable you to access our Website. This data is stored only for the duration of your session. The legal basis for this processing is our legitimate interest (Article 6(1)(f) GDPR) in providing our Website service.

          PROVISION OF THE WEBSITE AND CREATION OF LOG FILES

            Each time our Website is accessed, our system automatically collects data and information from the device (e.g. computer, mobile phone, tablet, etc.) used to access it.

            5.1 Collecting Data Anonymously

            Our Website can be accessed without disclosing your identity. We only collect technical information such as your internet service provider’s name, the referring website, and the corporate pages you visit. This data, along with date and time information, is evaluated for internal statistical purposes concerning advertising, site analysis, and improving our websites’ user experience. Throughout this process, you maintain complete anonymity as a user. We do not create pseudonymized user profiles.

             5.2 Types of Personal Data Collected and the Extent of their Processing

            1. Type and version of the web browser used;
            2. Operating system of the accessing device;
            3. Hostname of the accessing computer; 
            4. IP address of the accessing device;
            5. Date and time of access;
            6. Websites and resources accessed on our Website, including images, files, and other page content; 
            7. Referrer tracking data, indicating the other sites from which the user’s system accessed our Website; 
            8. Access status, indicating whether the retrieval was successful or resulted in a failure; 
            9. Quantity of data transmitted.

            5.3  Data Retention Period

            Deleting the aforementioned technical data takes place as soon as they are no longer required to ensure the Website’s compatibility for all visitors, but no later than 3 months after accessing our Website.

            5.4 Objection to Data Collection

            You can object to the processing at any time under Article 21 of the GDPR and request the deletion of data in accordance with Article 17 of the GDPR.

            YOUR RIGHTS AS A DATA SUBJECT

              6.1 Right of access by the data subject (right to information) (Art. 15 GDPR)

              You have the right to request information about whether we process your personal data, and if so, to access that data and the information detailed in Article 15 of the GDPR.

              6.2 Right to rectification (Art. 16 GDPR)

              The GDPR includes a right for individuals to have inaccurate personal data rectified, or completed if it is incomplete.

              6.3 Right to erasure (Art. 17 GDPR)

              The  GDPR introduces a right for individuals to have personal data erased (also known as ‘the right to be forgotten’) if one of the reasons listed in Art. 17 GDPR applies. The right is not absolute and only applies in certain circumstances.

              Pursuant to Art. 17 (1) of the GDPR, you have the right to demand that we delete the personal data we have collected about you if: a) the data is either no longer required; b) the legal basis for the processing has ceased to exist without replacement due to the withdrawal of your consent; c) you have objected to the processing and there are no legitimate grounds for processing; d) your data is processed unlawfully; e) a legal obligation requires this or a collection pursuant to Art. 8 (1) GDPR has taken place.

              Pursuant to Article 17 (3) of the GDPR, this right does not exist if: a) processing is necessary for the exercise of the right to freedom of expression and information; b) your data have been collected on the basis of a legal obligation; c) processing is necessary for reasons of public interest; d) the data are necessary for the assertion, exercise or defence of legal claims.

              6.4 Right to restriction of processing (Art. 18 GDPR)

              You have a limited right of restriction of processing of your personal data by a data controller (if one of the conditions listed in Art. 18 GDPR is met. Where the processing of your data is restricted, it can be stored by the data controller, but most other processing actions, such as deletion, will require your permission.

              According to Art. 18 (1) GDPR, you have the right in individual cases to demand the restriction of the processing of your personal data. This is the case when: a) the accuracy of the personal data is disputed by you; b) the processing is unlawful and you do not consent to its erasure; c) the data is no longer needed for the purpose of processing, but the collected data is used for the assertion, exercise or defence of legal claims; d) an objection to the processing has been lodged pursuant to Art. 21 (1) GDPR and it is still unclear which interests prevail.

              6.5 Right to data portability (Art. 20 GDPR)

              In certain cases, which are listed in detail in Art. 20 GDPR, you have the right to receive the personal data concerning you in a structured, commonly used and machine-readable format or to request the transmission of this data to a third party.

              6.6 Right to object (Art. 21 GDPR)

              Under Article 21 GDPR, you have the right to object when the processing of your data is based on legitimate interest. A legitimate interest is an interest of a company that outweighs the rights of a user. For example, the use of data for legitimate security reasons. In essence, this is a balancing test between your rights and the interests of the Company. We will then no longer process the personal data unless there are demonstrably compelling legitimate grounds for the processing that override your interests, rights, and freedoms, or the processing serves the establishment, exercise or defence of legal claims.

              6.7 Right to withdraw consent (Art. 7 GDPR)

              If the processing of data is based on your consent, you are entitled to withdraw your consent to the use of your personal data at any time in accordance with Art. 7 para. 3 GDPR. Please note that the revocation only takes effect in the future. Processing that took place before the revocation is not affected.

              6.8 Right to lodge a complaint with a supervisory authority (Art. 77 GDPR)

              If you believe your data is being processed unlawfully on our site, you have the right to seek legal remedies through the courts. You also have the right to lodge a complaint with a supervisory authority under Article 77(1) GDPR. You can file a complaint in the EU Member State where you live, work, or where the alleged infringement occurred. The supervisory authority will inform you of the status and outcome of your complaint, including information about your right to a judicial remedy under Article 78 GDPR.

              6.9 How to exercise your rights

              You can exercise your rights at any time by contacting us using the contact details below:

              Hermeshaul Limited

              Address: 9/F, AMTEL BUILDING, 148 DES VOEUX ROAD CENTRAL, CENTRAL, HONG KONG 

              Website: https://hermeshaul.com/

              Email: privacy@…

              We shall reply to your requests as soon as possible and, in all cases, within the term of one month from receipt of your application. That term may be extended for a further two months if necessary, bearing in mind the complexity and number of applications. The controller shall inform the data subject of the extension within the first month of the application.

              INFORMATION ON THE USE OF COOKIES

                We use cookies to improve your Website experience and provide smooth navigation. We use cookies which are temporary and deleted when you close your browser or after a period of inactivity. These cookies help us track which content you view during your session and enhance your security.

                Cookies cannot harm your computer and do not pose a security risk like viruses or spyware. You can manage your cookie preferences through your browser settings.

                We also use cookies to make our Website more user-friendly. Additionally, we use cookies to analyse user browsing behaviour. 

                7.1 Purpose and Legal Basis of Data Processing

                We use two types of cookies: essential (strictly necessary) cookies and analytics (performance) cookies.

                Essential Cookies: These cookies are strictly necessary for our Website to function correctly. They enable core website features, such as remembering your language settings as you navigate between pages. The legal basis for processing data using essential cookies is our legitimate interest in providing Website functionality (Article 6(1)(f) GDPR). These cookies do not create user profiles.

                Analytics Cookies: These cookies help us analyse how users interact with our Website, such as which search terms are used. This information allows us to improve our Website and services. The legal basis for processing data using analytics cookies is your consent (Article 6(1)(a) GDPR).

                7.2  Data Storage and Your Cookie Choices

                Cookies are stored on your computer and sent to our Website by your browser. You have full control over the use of cookies through your browser settings. You can disable or restrict cookies, and you can delete existing cookies at any time. Please note that disabling cookies may affect the functionality of our Website.

                7.3 Duration of storage

                Our cookies are stored until they are deleted in your browser or, if they are session cookies, until the session has expired.

                7.4 Browser settings

                You can control cookies through your browser settings. Keep in mind that blocking cookies might stop some parts of our Website from working correctly.

                See below for instructions on how to manage cookies in different browsers:

                Google Chromehttps://support.google.com/chrome/answer/95647?hl=en&co=GENIE.Platform%3DDesktop
                Windows Explorerhttps://support.microsoft.com/en-us/topic/how-to-delete-cookie-files-in-internet-explorer-bca9446f-d873-78de-77ba-d42645fa52fc
                Firefoxhttps://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences?redirect=no
                Apple Safarihttp://support.apple.com/kb/ph5042

                7.5 Consent

                We inform you that the Company in its domain hermeshaul.com, does not use any type of “cookie” for the processing of personal data that allows the identification of specific natural persons.

                Upon reading this Policy, users are hereby notified that continued use of this Website without taking appropriate steps to configure their browser settings to block cookies constitutes consent to the use of cookies as detailed herein. 

                DATA TRANSFER RECEIVERS AND INTERNATIONAL DATA TRANSFER RECEIVERS

                  No personal data will be transferred to third parties or international organizations. Furthermore, we do not anticipate any international transfers of personal data.

                  UPDATE OF THIS POLICY

                    The Company reserves the right to modify this Policy to comply with new legislation, jurisprudence, or industry standards. We will provide advance notice of any changes on our Website and, where required, obtain consent from affected individuals.

                    If you have any questions or comments regarding this Policy, please contact us at: privacy@…