Introduction
This Privacy Policy explains how HongKong CNGR Zhongheng New Energy Co., Limited handles personal information in the course of running its cell stack hall and its related services. The company is referred to in this policy as the Company. The policy is issued under the oversight of CNGR Zhongheng, the developer responsible for the Company systems and the hall records described below.
The Company operates a physical hall in Causeway Bay where module orders are booked, batches are certified and dispatch notes are written. Most of the information the Company holds comes from that hall activity rather than from online advertising. The policy therefore describes both the information a client sends to the Company and the information the Company records as part of the work it performs. The policy is written in plain English so that a client can understand what happens to information after it reaches the hall.
By contacting the Company, booking a module order, requesting a certification run or using the Company website, a person accepts the practices described in this policy. If a person does not accept these practices, that person should not send personal information to the Company and should contact the Company to discuss an alternative arrangement.
Scope of this policy
This policy applies to personal information that the Company collects through its website, through email and telephone correspondence, and through the day to day operation of the cell stack hall. It covers information about clients, prospective clients, suppliers, carriers, visitors to the hall and any other person who interacts with the Company.
The policy does not apply to information that the Company receives about a business rather than an individual, except where that business information includes the name or contact details of a person. Where a business supplies the name of an employee or a contact, that name is treated as personal information and is handled according to this policy.
The policy also does not apply to third party websites that a person may reach from a link on the Company website. Those websites are governed by their own policies, and the Company encourages a visitor to read the policy of any site before sending information to it.
Who we are
HongKong CNGR Zhongheng New Energy Co., Limited is a company registered in Hong Kong and operating in the field of computer systems design and related professional services. The Company runs a cell stack hall at Rm 1911 Lee Garden One, 33 Hysan Ave, Causeway Bay, Hong Kong - 999077, Hong Kong (HK). The hall is the centre of the Company order intake, and it is where the records described in this policy are created and kept.
For the purposes of applicable data protection law, the Company is the controller of the personal information described in this policy. This means the Company decides why information is collected and how it is used. The developer CNGR Zhongheng supports the Company in maintaining the records and the technical systems that hold them, and that support is carried out under the instructions of the Company.
Information we collect
The Company collects several categories of personal information. The categories below describe the information most often received, and the list is not exhaustive. Where a new category arises in the course of a booking, the Company records it in the same way as the categories listed here.
- Identity information. A name, the name of a business, a job title and the role a person holds in a booking.
- Contact information. An email address, a telephone number, a postal address and, where a pack is to be collected, the name of a nominated contact.
- Order information. The tray count, stack height, target dispatch quarter and any instructions that a client gives when booking a module order.
- Certification information. The batch number, the readings written on a run sheet, the time of each reading and any deviation noted in the margin of the sheet.
- Logistics information. The carrier, the route, the pack count and the handover contact written on a logistics note.
- Correspondence. The content of emails, letters and telephone notes exchanged with the Company about a booking or a review.
- Website information. Technical information sent by a browser when a person visits the Company website, such as the type of device and the pages visited.
- Visitor information. The name and business of a person who visits the hall, together with the time of arrival and the purpose of the visit.
The Company does not ask for information that is not needed for the activity being performed. A person who books a module order is asked for order information because the bay slip cannot be written without it. A person who arranges a dispatch is asked for logistics information because the note at the door cannot name a carrier without it. The Company avoids collecting information on the chance that it might be useful later.
How we collect information
Most information is collected directly from the person concerned. A client supplies order information when booking at a module order bay, or by email or telephone. A carrier supplies logistics information when collecting a pack from the dispatch door. A visitor supplies identity information at the hall entrance on the day of the visit.
Some information is created by the Company rather than supplied by a person. The readings written on a certification run sheet are created by a technician during the run. The check marks on a pack line check sheet are created by the line checker. The bound copy of a logistics note is created by the desk clerk at the dispatch door. This created information forms part of the record of work, and it is handled in the same way as information supplied directly.
A small amount of website information is collected automatically when a person visits the Company site. This information is used to keep the site working correctly and to understand which pages are useful. It is not used to build a profile of a visitor, and it is not combined with order information.
Why we use information
The Company uses personal information for purposes that are directly connected with the hall activity. The main purposes are set out below.
- To book a module order and to write the bay slip that records it.
- To set a batch on a test stand, take the readings and file the run sheet.
- To check a pack on the line and to sign the check sheet beside the pack number.
- To write a logistics note for a movement and to give the note to the carrier at the door.
- To release a sample inside a dispatch window with the relevant run line enclosed.
- To conduct a quarter order review and to send a written summary to the client.
- To answer enquiries about a booking, a pack or a shipment.
- To keep the records the Company needs to run the hall and to meet its obligations.
- To maintain the website and to protect it from misuse.
The Company does not use personal information for a purpose that is unrelated to the hall activity unless the person concerned has been told about the new purpose and has agreed to it. Where the Company wishes to use information for a new purpose, it will explain the purpose in plain English and will give the person a reasonable chance to object.
Legal basis for processing
The Company relies on several legal grounds when it handles personal information. Where a person books an order or asks for a certification run, the Company handles information because it is needed to perform the service that has been requested. Where a person visits the hall, the Company handles identity information because it has a legitimate interest in knowing who is on the floor and in keeping the hall safe.
Where the Company is required by law to keep a record, for example a dispatch note that supports a movement of goods, it handles the information because it has a legal obligation to do so. Where the Company wishes to send a marketing update, it relies on the agreement of the person concerned and offers an easy way to withdraw that agreement at any time.
A person who has a question about the legal ground used for a particular activity may write to orders@cngrzhongheng.mom and ask for an explanation. The Company will answer in plain English and will describe the ground it relies on and the reason that ground applies.
Carriers and logistics partners
Carriers and logistics partners play a central role in the Company work, and the Company shares a limited set of information with them. The information shared is the information written on the logistics note, together with any instruction needed to complete a handover. A carrier does not receive certification readings or order pricing, because those details are not needed to move a pack from the door to its destination.
The logistics note desk keeps a bound copy of every note, and that copy is retained even after the carrier has completed the movement. A carrier who asks the Company to confirm a movement is answered from the bound copy. Where a carrier changes a route after the note is written, the change is recorded beside the original line and initialled, and the carrier is told that the original note still stands as the record of the movement.
A carrier that handles a pack is a separate organisation, and its handling of information is governed by its own policy. The Company chooses carriers with care, but it cannot control the internal practices of a carrier. A client who has a concern about a carrier should raise it with the Company, and the Company will pass the concern to the carrier and ask for a response.
Certification and order records
Certification run sheets and bay slips are records of work, and they are kept for longer than ordinary correspondence. The Company keeps a run sheet because it is the single point of truth for what was measured on a batch. A client may ask about a batch years after it was certified, and the Company answers from the run sheet that was filed at the time. The run sheet therefore holds the batch number, the readings and the time of each reading, and it is retained for the period described in the retention section of this policy.
Bay slips are kept because they connect an order to the batch that fulfilled it. A quarter order review compares bay slips, run sheets and logistics notes, and the review cannot be conducted without all three. The Company keeps the slips in a form that can be read without a terminal, so that a review can be answered even if the electronic ledger is unavailable.
Where a person asks for a copy of a run sheet or a bay slip, the Company will provide it unless the sheet contains information about another person that should not be disclosed. In that case the Company will provide the parts that relate to the person making the request and will explain why the other parts were withheld.
Retention of information
The Company keeps personal information only for as long as it is needed for the purpose for which it was collected. The retention period depends on the type of information and on the activity concerned.
- Correspondence about an enquiry that does not lead to a booking is kept for a short period and then deleted.
- Bay slips are kept for the period needed to support quarter order reviews and any later question about an order.
- Certification run sheets are kept for a longer period, because they are the record of what was measured on a batch.
- Logistics notes are kept for the period needed to support a movement and to answer a carrier question.
- Visitor information is kept for a short period, because it is used only to know who was in the hall on a given day.
When a retention period ends, the Company deletes the information or removes the parts that identify a person. Where information is held in a bound paper file, the Company disposes of the file securely. Where information is held in an electronic ledger, the Company removes it from the live ledger and from the backups within the period described in its internal schedule.
Security measures
The Company takes the security of personal information seriously. Access to the electronic ledger is limited to staff who need to use it for the hall activity. Each staff member has a separate account, and the accounts are reviewed when a staff member changes role or leaves the Company. The hall is locked outside business hours, and the review room is kept locked when it is not in use.
Paper records are kept in bound files and in locked cabinets. A bound file is never left open on a desk overnight, and a file that is taken to a station is returned to its cabinet at the end of the day. The printed ledger structure kept in the review room is signed by the clerk who made the change, so that an alteration can be traced to a person and a date.
The Company reviews its security measures at regular intervals. Where a weakness is found, the Company corrects it and records the correction. If a security incident affects personal information, the Company will investigate the incident, take steps to reduce the harm, and notify the affected persons and any relevant authority where the law requires it.
International transfers
The Company operates from Hong Kong, and most information is held in Hong Kong. Some service providers that support the website or the electronic ledger may hold information outside Hong Kong. Where information is transferred outside Hong Kong, the Company takes steps to ensure that it is protected to a standard consistent with this policy.
The steps taken include written agreements with service providers, the use of providers that apply recognised security practices, and a review of the legal environment in the destination country before a transfer is made. Where the Company cannot ensure an adequate standard of protection, it will not make the transfer.
A person who wishes to know whether information about that person has been transferred outside Hong Kong may write to the Company and ask. The Company will explain the destination and the protection applied, unless the law prevents disclosure.
Your rights
A person has several rights in relation to the personal information that the Company holds. The Company respects these rights and will act on a valid request within the period required by law.
- Right of access. A person may ask for a copy of the personal information the Company holds about that person.
- Right of correction. A person may ask the Company to correct information that is inaccurate or incomplete.
- Right of deletion. A person may ask the Company to delete information where there is no good reason for the Company to keep it.
- Right of restriction. A person may ask the Company to stop using information while a question about it is resolved.
- Right of objection. A person may object to the use of information for a particular purpose.
- Right of portability. A person may ask for information in a form that can be moved to another service.
- Right to withdraw agreement. A person may withdraw agreement to a use that relies on agreement, such as a marketing update.
A right is not absolute. Where the Company is required by law to keep a record, it may decline a request for deletion and will explain the reason. Where a request would disclose information about another person, the Company may remove that part of the record before providing a copy.
Making an access request
An access request should be sent to orders@cngrzhongheng.mom or by post to Rm 1911 Lee Garden One, 33 Hysan Ave, Causeway Bay, Hong Kong - 999077, Hong Kong (HK). The request should describe the information sought and should include enough detail for the Company to identify the person making the request.
The Company may ask for proof of identity before providing a copy of personal information. This step protects the person concerned, because it prevents another party from obtaining a record that does not belong to it. The proof requested will be the minimum needed to confirm identity.
The Company will acknowledge an access request within a reasonable period and will provide the information within the period required by law. Where a request is complex, the Company will explain the reason for any delay and will keep the person informed. A request may also be made by telephone on +17432668256, although the Company may ask for the request to be confirmed in writing before releasing a record.
Privacy for children
The Company services are intended for businesses and for adults acting in a professional capacity. The Company does not knowingly collect personal information from a child. A module order bay, a certification run and a quarter order review are all business activities, and a booking is not accepted from a person who identifies as a child.
If the Company learns that it holds personal information about a child, it will delete the information as soon as it can, unless the law requires the Company to keep it. A parent or guardian who believes that a child has sent information to the Company should contact orders@cngrzhongheng.mom, and the Company will act on the request promptly.
The Company website is not directed at children, and the content is written for a professional audience. The Company does not use the site to collect information from children and does not run contests or promotions aimed at children.
Marketing and updates
The Company sends marketing updates only to a person who has agreed to receive them. An update may describe a new service, a change to the quarter order window or a note about the hall. The Company does not send an update to a person who has asked to stop receiving them.
A person may withdraw agreement at any time by using the unsubscribe link in an update or by writing to orders@cngrzhongheng.mom. The Company will act on the request promptly and will keep a record of the request so that the person is not added again by mistake.
The Company does not share a marketing list with another party. Where an update is sent by a service provider on behalf of the Company, the provider is bound by a written agreement and may not use the list for any other purpose.
Third party links
The Company website may contain a link to a website operated by another party. A link is provided for convenience and does not mean that the Company endorses the practices of the other site. The Company does not control the content of a linked site and is not responsible for the way that site handles personal information.
A person who follows a link should read the privacy policy of the site that is reached before sending information to it. If a linked site appears to misuse information, the person may report the matter to the Company, and the Company will consider whether the link should remain.
Changes to this policy
The Company may change this policy from time to time. A change may be made to reflect a new service, a change in the law or an improvement in the way information is handled. When a change is made, the Company will update the policy on this page and will note the date of the revision.
Where a change is significant, the Company will take reasonable steps to bring it to the attention of persons who are likely to be affected. Those steps may include a notice on the website or a message to clients with an active booking. A person who continues to use the Company services after a change takes effect is treated as accepting the revised policy.
The Company encourages a client to read this policy from time to time so that the client is aware of the current practices. A copy of the current policy is available from the hall on request.
Complaints and contact
A person who has a concern about the way the Company handles personal information should contact the Company first. A concern may be sent to orders@cngrzhongheng.mom or by post to Rm 1911 Lee Garden One, 33 Hysan Ave, Causeway Bay, Hong Kong - 999077, Hong Kong (HK). The Company will acknowledge the concern and will investigate it with care.
The Company will reply in plain English and will explain what it has found and what it proposes to do. Where the Company has made a mistake, it will say so and will correct the record. Where the Company believes it has acted correctly, it will explain the reason and will tell the person what further step is available.
A person who is not satisfied with the response of the Company may complain to the relevant data protection authority in Hong Kong. The Company will cooperate with any such authority and will provide the information needed to resolve the complaint. The Company prefers to resolve a concern directly, and it asks that a person contact the hall before taking the matter further.
For any question about this policy, the contact details are: HongKong CNGR Zhongheng New Energy Co., Limited, Rm 1911 Lee Garden One, 33 Hysan Ave, Causeway Bay, Hong Kong - 999077, Hong Kong (HK). Email orders@cngrzhongheng.mom. Telephone +17432668256. The policy is issued by the Company and supported by the developer CNGR Zhongheng.