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Privacy policy

What we collect when you send us an enquiry, why we hold it, who else sees it, how long we keep it, and how to ask us to change or delete it.

1. Who we are

This policy describes how we collect, use and protect your personal data when you visit www.kawaygroup.com or contact us through it. The data controller is Kaway Group Limited.

Controller
Kaway Group Limited
Company number
2317362, Hong Kong Companies Registry
Business Registration Number
65561489
Registered office
Room 2105, SH2822, Trend Centre, 29-31 Cheung Lee Street, Chai Wan, Hong Kong
Contact
hello@kawaygroup.com

2. Scope

This policy covers personal data collected through the website. We process it in accordance with the data protection law that applies to you: the General Data Protection Regulation, Regulation (EU) 2016/679, for visitors in the European Economic Area, the UK GDPR for visitors in the United Kingdom, and the Personal Data (Privacy) Ordinance, Cap. 486, in Hong Kong.

3. What we collect

3.1 What you send us through the enquiry form

The form asks for your name and email address, which are required, and for your company if you want to give it. You then describe what you need, and you may add the quantity, the reader or lock system you use, an approximate delivery date, a file with your artwork or a specification up to 10 MB, and a link to a file held somewhere else.

Please send only what is needed to answer your enquiry. The form is not the place for confidential technical documentation or for anyone else's personal data. If you share a link instead of a file, the service hosting it is outside our control and its own terms apply.

3.2 What you send us by email

If you write to us directly, we hold your message, your address and anything you attach, for as long as we need it to deal with the matter.

3.3 What is collected automatically

Our hosting provider records standard technical data in its server logs when a page is requested: the IP address, the browser and device type, the page requested and the time. This is used to deliver the site, to keep it secure and to detect abuse. We do not run analytics on this website, we build no profile of you and we do not track you across other sites. See our Cookies policy.

4. Why we use it, and on what legal basis

  • To answer your enquiry, prepare a quotation and send you samples: steps taken at your request before entering into a contract, Article 6.1.b GDPR, and our legitimate interest in handling business enquiries, Article 6.1.f.
  • To manage an order and the relationship that follows it: performance of a contract, Article 6.1.b.
  • To keep the website available and secure: our legitimate interest in protecting our systems, Article 6.1.f.
  • To send commercial information about our products to customers and to contacts who have asked for it: our legitimate interest in maintaining a business relationship, Article 6.1.f, or your consent where the law requires it, Article 6.1.a. Every message carries a way to stop receiving them.
  • To meet accounting, tax and other legal obligations: compliance with a legal obligation, Article 6.1.c.

We will not use your data for a purpose that is incompatible with these without telling you first.

5. Who else sees it

We do not sell your personal data and we do not share it for advertising. We use a small number of service providers to run the website and to communicate with you:

  • Webflow, Inc., United States: website hosting, and storage of the enquiries submitted through the form.
  • Microsoft Corporation, United States and European Union: business email and office software, through which we receive and answer your enquiry.

Each acts as a processor on our instructions, under a contract that requires it to protect the data and to use it only for the service it provides. Within Kaway Group, access is limited to the people who need it to answer you.

We also disclose data where the law, a court or a competent authority requires it. If the business is ever sold or merged, data may pass to the acquirer, who would be held to the commitments made here.

6. International transfers

Kaway Group Limited is established in Hong Kong and some of our providers are in the United States, so your data is transferred internationally.

For visitors in the EEA and the United Kingdom, where a transfer goes to a country that has not been recognised as offering an adequate level of protection, we rely on appropriate safeguards: the Standard Contractual Clauses approved by the European Commission, the UK addendum where it applies, or the recipient's certification under the EU-U.S. Data Privacy Framework. You can ask us for details of the safeguards used by writing to hello@kawaygroup.com.

7. How long we keep it

  • Enquiries that do not lead to an order, including any file attached: up to 24 months from the last contact, then deleted.
  • Customer records: for the length of the relationship and up to 6 years afterwards, to meet accounting and commercial law obligations.
  • Artwork and specifications for an order: for as long as we may reasonably be asked to reproduce that order, and then deleted or returned on request.
  • Server logs: for the short period our hosting provider retains them for security purposes.

After the applicable period the data is deleted or anonymised.

8. Your rights

If you are in the European Economic Area or the United Kingdom you have the right to ask for access to your personal data, to have it corrected, to have it erased, to restrict how we use it, to receive it in a portable format, and to object to processing based on our legitimate interest. Where processing rests on consent, you can withdraw it at any time, which does not affect what was done before.

In Hong Kong, the Personal Data (Privacy) Ordinance gives you the right to ask whether we hold data about you, to obtain a copy and to request correction.

Write to hello@kawaygroup.com to exercise any of these. We answer within one month, and we may ask you to confirm your identity first so that we do not disclose your data to somebody else.

If you are not satisfied with our answer, you can complain to the data protection authority of the country where you live or work. In Hong Kong this is the Office of the Privacy Commissioner for Personal Data.

9. Security

We apply technical and organisational measures appropriate to the risk: encrypted connections, access limited to the people who need it, and providers chosen for their own security standards. No transmission over the internet and no method of storage can be guaranteed completely secure, and we will tell you and the relevant authority if a breach ever requires it.

10. Do Not Track

Some browsers send a Do Not Track signal. There is no agreed standard for how a website should respond to one, so we do not act on it. In practice it changes nothing here, because this website does not track you.

11. Children

This is a business to business website and it is not directed at children under 16. We do not knowingly collect data from them. If you believe a child has sent us personal data, write to hello@kawaygroup.com and we will delete it.

12. Changes to this policy

We may update this policy as our practices or the legal framework change. The date at the top shows the latest revision, and we recommend you look at it from time to time.

13. Contact

For any question, request or complaint about this policy or about how we handle your personal data, write to hello@kawaygroup.com or to Kaway Group Limited, Room 2105, SH2822, Trend Centre, 29-31 Cheung Lee Street, Chai Wan, Hong Kong.