Data protection notice for third parties (O_IS_HK)

August 2026

 

This Data Protection Notice sets out the basis on which Technoform Bautec Hong Kong Limited collects, uses, discloses or otherwise processes the personal data of third parties, in accordance with the Personal Data (Privacy) Ordinance (Cap. 486) of Hong Kong (“PDPO”). It applies to personal data in our possession or under our control, including personal data held by organisations we have engaged to process it on our behalf.

In this Notice, “third party” means an individual who is not our employee, customer, job applicant or business partner, but whose personal data we may process in connection with our business activities — including individuals who contact us, emergency contacts, authorised representatives, visitors, witnesses, complainants, or individuals identified in correspondence or contractual documentation. “personal data” means any data: (a) relating directly or indirectly to a living individual; (b) from which it is practicable for the identity of the individual to be directly or indirectly ascertained; and (c) in a form in which access to or processing of the data is practicable.

 

1  Data Controller 

The organisation responsible for the processing of your personal data is:

Technoform Bautec Hong Kong Limited
2 Chun Cheong Street, Tseung Kwan O Industrial Estate,
Tseung Kwan O, Kowloon, Hong Kong

T +852 2665 6322
E info [dot] tesg [at] ap [dot] technoform [dot] com (info[dot]tesg[at]ap[dot]technoform[dot]com)

For any questions regarding data protection, you may contact our Data Protection Contact using the details set out in Section 5 at any time.

2  Purpose and legal basis

We process your personal data on the basis of the PDPO and all other laws relevant to us in matters of data protection. As a third party, we typically process your personal data to appropriately organise and conduct our business operations — for example, where you contact us without a contract being initiated, or where you have been named as a contact person in the course of our provision of services to our customers. Where we rely on your consent, you may withdraw it at any time (see Section 4). Where permitted or required by the PDPO or other laws, we may also collect, use or disclose your personal data without consent. We process the following categories of personal data:

  • name;
  • address;
  • contact details (email address and telephone number);
  • other data that you provide to us as part of your request, or that is necessary to process your request.

We may collect and use your personal data for any or all of the following purposes: performing obligations in the course of, or in connection with, our provision of goods and/or services to our customers; verifying your identity; responding to, handling and processing queries, requests, applications, complaints and feedback from you; fraud detection and prevention; complying with any applicable laws, regulations, codes of practice, guidelines or rules, or to assist in law enforcement and investigations conducted by any governmental or regulatory authority; and any other purposes for which you have provided the information.

Without providing the required data, we may not be able to process your request. These purposes may continue to apply even after our relationship with you has ended or been altered (for example, pursuant to a contract), for a reasonable period thereafter, including to enable us to enforce our rights under any contract.

3  Recipients of personal data

We will only disclose your personal data to third parties where necessary to fulfil the purposes set out above, including performing obligations in the course of, or in connection with, our provision of goods and services to our customers. Data may also be disclosed to government authorities and regulatory bodies where required or authorised by law. Where we engage data intermediaries, we require them, by contract, to protect your personal data in a manner consistent with the PDPO and this Notice.

4  Your rights

Subject to the PDPO and applicable exceptions, you have the following rights in relation to your personal data:

4.1  Withdrawal of consent

Where we rely on your consent, that consent remains valid until withdrawn in writing. You may withdraw consent for any or all of the purposes above by submitting a written request to our Data Protection Contact. Upon receipt, we may require reasonable time to process your request and will notify you of the likely consequences, and we shall generally seek to do so within ten (10) business days. Please note that, depending on the nature and scope of your request, we may be unable to continue providing our goods or services to you, in which case we will notify you before completing the processing of your request. Withdrawing consent does not affect our right to continue processing personal data where permitted or required under applicable law.

4.2  Access and correction

Under the PDPO, you have the right to request access to, and correction of, your personal data held by us. Such requests should be submitted in writing to our Data Protection Contact. A reasonable fee may be charged for an access request, and we will inform you of the fee beforehand. We will generally respond within twenty-one (21) business days; if we are unable to do so within thirty (30) days, we will inform you in writing of the time by which we will respond.

4.3  Accuracy of personal data

We generally rely on the personal data provided by you (or your authorised representative). To ensure your personal data remains current, complete and accurate, please inform our Data Protection Contact in writing of any changes to your personal data.

4.4  Protection of personal data

To safeguard your personal data from unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks, we have implemented appropriate administrative, physical and technical measures. These include minimised data collection, authentication and access controls, encryption, up-to-date antivirus protection, regular patching, secure disposal of storage media, and the use of two-factor or multi-factor authentication. While no method of transmission or storage is completely secure, we continually review and enhance our information security measures.

4.5  Retention of personal data

We retain your personal data for as long as necessary to fulfil the purposes for which it was collected, or as required or permitted by applicable law. In general, third-party personal data is retained for up to three (3) years after the conclusion of the matter to which it relates, unless a longer period is required or permitted by law. We will cease to retain your personal data, or remove the means by which it can be associated with you, as soon as it is reasonable to assume that retention no longer serves those purposes and is no longer necessary for legal or business purposes.

4.6  Transfers of personal data outside Hong Kong

We generally do not transfer your personal data to places outside Hong Kong. However, where we do so — including transfers to other companies within the Technoform Group or to cloud-based service providers — we will take steps to ensure that your personal data continues to receive a standard of protection comparable to that required under the PDPO, and will obtain your consent where required.

4.7  Data breach notification

In the event of a personal data breach, we will assess the incident promptly and take appropriate remedial measures. Where appropriate, and in accordance with the guidance issued by the Office of the Privacy Commissioner for Personal Data, we may notify the PCPD and affected individuals.

4.8  Direct marketing consent

We will not use your personal data for direct marketing purposes without first obtaining your explicit consent. If you consent, you may withdraw such consent at any time, without charge, by contacting our Data Protection Contact.

5 Data Protection Contact

You may contact our Data Protection Contact if you have any enquiries or feedback on our personal data protection policies and procedures, or if you wish to make any request in relation to your personal data:

Contact number: +852 2665 6322
Email: info [dot] tesg [at] ap [dot] technoform [dot] com (info[dot]tesg[at]ap[dot]technoform[dot]com)

All enquiries sent to this mailbox will be reviewed and handled by our designated compliance staff in accordance with the PDPO.

6  Validity and modification of this Notice

This Notice is currently valid (see date in the heading) and applies in conjunction with any other policies, notices, contractual clauses and consent clauses relating to the collection, use and disclosure of your personal data by us. Due to the further development of our offerings, or changes in legal or regulatory requirements, it may become necessary to amend this Notice from time to time without prior notice. You may determine whether any revision has taken place by referring to the date on which this Notice was last updated. Your continued use of our services constitutes your acknowledgement and acceptance of any such changes.