Brasia Limited needs to collect personal information about people with whom it deals in order to carry out its business and provide its services. Such people include clients, employees (present, past and prospective), suppliers and other business contacts. The information includes name, address, email address, private and confidential information, sensitive information, etc. In addition, we may occasionally be required to collect and use certain types of such personal information to comply with the requirements of the law. No matter how it is collected, recorded and used (e.g. on a computer or other digital media, on hardcopy, paper or images) this personal information must be dealt with properly to ensure compliance with the General Data Protection Regulation Regulation (EU) 2016/679.
The lawful and proper treatment of personal information by Brasia Limited is extremely important to the success of our business and in order to maintain the confidence of our service users and employees. We ensure that Brasia Limited treats personal information lawfully and correctly.
“Company” means Brasia Limited, a private company incorporated under the laws of Hong Kong.
“GDPR” means the General Data Protection Regulation Regulation (EU) 2016/679.
“ICO” means Information Commissioner’s Office.
“Data subjects” means the ceding party of the personal information.
“Personal data” means all data disclosed by the Data subject such as name, email, contact number, address, gender, financial information, transaction information, technical data, copies of personal documents, etc.
The Company is committed to processing Personal data in accordance with its responsibilities under the GDPR.
Article 5 of the GDPR requires that personal data shall be:
a. processed lawfully, fairly and in a transparent manner in relation to individuals;
b. collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes; further processing for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes shall not be considered to be incompatible with the initial purposes;
c. adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed;
d. accurate and, where necessary, kept up to date; every reasonable step must be taken to ensure that personal data that are inaccurate, having regard to the purposes for which they are processed, are erased or rectified without delay;
e. kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed; personal data may be stored for longer periods insofar as the personal data will be processed solely for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes subject to implementation of the appropriate technical and organisational measures required by the GDPR in order to safeguard the rights and freedoms of individuals; and
f. processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures.
a. Data subjects can register on the Company’s website, which involves providing Personal data. The Personal data sent is defined in the input screen used for registration, and once entered it is collected and stored solely for the specified purpose;
b. Data subjects can subscribe to newsletters on the Company’s website. The Personal data sent is as defined in the input screen used for subscribing. The Company regularly informs its customers and prospects about services and updates by means of a newsletter. Data subjects can only receive the newsletter if they have a valid e-mail address and they have registered for the newsletter or have a relationship with the Company and the newsletter in question contains information of relevance;
c. Data subjects can contact the Company through the general email address provided on the website or using a contact form. Personal data given to the Company voluntarily in this way is stored so that the request can be handled, or the Data subject contacted;
d. The Company will process and store personal data related to prospects and clients for the purposes of:
• personalisation of content, business information or user experience
• account set up and administration
• delivering marketing and events communication
• carrying out polls and surveys
• internal research and development purposes
• providing goods and services
• legal obligations (eg. prevention of fraud, anti-money laundry procedures, governmental and tax obligations)
• meeting internal audit and compliance requirements;
e. Data subjects can cancel their subscriptions to the newsletter at any time and withdraw their consent to storage of Personal data they provided. Every newsletter contains a link that can be used to withdraw consent. Data subjects can also cancel their subscriptions to the newsletter at any time directly emailing the Company. The company will endeavor to only store data that is required by law and inform the Data subject if any information is required by law to be disclosed.
4. General provisions
a. This policy applies to all Personal data processed by the Company;
b. The Compliance officer shall take responsibility for the Company’s ongoing compliance with this policy;
c. This policy shall be reviewed at least annually;
d. To ensure its processing of data is lawful, fair and transparent, the Company shall maintain a Register of all data to be reviewed at least annually;
e. Individuals have the right to access their personal data and any such requests made to the Company shall be dealt with in a timely manner;
f. All data processed by the Company must be done on one of the following lawful bases: consent, contract, legal obligation, vital interests, public task or legitimate interests;
g. The Company shall note the appropriate lawful basis in the Register of all data;
h. Where consent is relied upon as a lawful basis for processing data, evidence of opt-in consent shall be kept with the personal data;
i. Where communications are sent to individuals based on their consent, the option for the individual to revoke their consent should be clearly available and systems should be in place to ensure such revocation is reflected accurately in the Company’s systems;
j. The Company shall ensure that Personal data are adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed;
k. All employees will observe all forms of guidance, codes of practice and procedures about the collection and use of Personal data.
5. Archiving and Removal
a. The Company shall ensure that Personal data is stored securely using modern software that is kept-up-to-date;
b. Access to Personal data shall be limited to personnel who need access and appropriate security should be in place to avoid unauthorised sharing of information;
c. When Personal data is deleted, it should be irrecoverable;
d. Appropriate back-up and disaster recovery solutions shall be in place;
e. The Company will only retain Personal data for as long as reasonably necessary to fulfil the purposes it was collected for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. The Company may retain Personal data for a longer period in the event of a complaint or if reasonably believes there is a prospect of litigation.
6. Breach of the Policy
a. In the event of a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, personal data, the Company shall promptly assess the risk to people’s rights and freedoms and if appropriate report this breach to the ICO within 72 hours of becoming aware of the breach;
b. If the breach is likely to result in a high risk of adversely affecting individuals’ rights and freedoms, the individuals shall be informed immediately;
c. The Company must keep a record of any Personal data breaches, regardless of whether it was required to notify.