In order for us to operate our business and provide our services to You, it is sometimes necessary for us to collect or process information about You. In general terms, this information will take one or more of the following forms:
- Information that you provide to us directly, such as in the situation where you complete an online form or send us a message via our website;
- Information that is automatically sent to us by Your computer’s internet browser when you visit our website, such as your computer’s technical address (or ‘IP address’) or information about which particular internet browser you are using and so on;
- Information about how you use our website or our services, such as which pages you visit, how frequently you visit the site and so forth.
Our commitment to your data privacy
We are fully committed to maintaining the privacy of any information (‘personal data’) that you provide to us. Furthermore, we commit to ensuring that such data is held securely, used appropriately and only retained for as long as is necessary.
We will never give, sell or otherwise transfer your personal data to a third party without your permission.
Our systems and services are designed with privacy in mind, and we operate a ‘data minimisation’ principle wherever possible – that is to say that we will only ever ask you for the minimum amount of information required to provide our services efficiently; we have no desire to retain (and therefore maintain) any more information than is necessary.
Considerations for website visitors from the European Union
We aspire to comply to the fullest extent possible with applicable data protection regulations, in particular the European Union’s General Data Protection Regulation (‘GDPR’) and ePrivacy Directive, where applicable.
Our role as data controller
In terms of your use of this website, We, Jet Express Technology Ltd, act in the capacity of Data Controller, and should you have any questions or concerns about the data we hold about you, we can be contacted using the information below:
Data Controller: Jet Express Technology Ltd
Correspondence address: Rm 805, 8/F, Harbour Crystal Centre, 100 Granville Road, TST, Hong Kong.
Email correspondence: email@example.com.
Definition of ‘personal data’
When we refer to ‘personal data’ we mean any information that allows us to identify you personally. Obvious examples include your name, email address, postal address etc. We will always seek to gain your explicit consent to providing this information before we collect it from you, although this may not be the only legal basis on which we collect the data.
Other types of information, such as your computer’s ‘IP’ address or broad geographical location do not, generally, allow us to identify you directly. However, because in their current form, European data privacy regulations are somewhat vague in this regard, we will cover the use of such data here also.
Website contact forms
Purpose & categories of data:
When you complete one of the contact forms on our website, we will ask you for a number of pieces of personal information, such as your name, email address and other contact details. This is obviously required for us to respond to your request.
This information will only be shared with Jet Express Technology Ltd employees (for the purpose of responding to your enquiry) and our trusted technology partners (such as our web development team) who have access to our systems for the purpose of maintenance, support and security.
Intent to contract (GDPR Art 6(1)(b)): Additionally, the information that you provide to us here is necessary for us to fulfil your request prior to entering into a contract.
Types of processing
- We may store the information you provide to us in our website database. Such storage allows us to efficiently access your data and respond to your requests;
- For the purpose of maintaining the integrity of our systems, we may also store this data in system backups, [which are encrypted and held securely by our technology partner Amazon Web Services];
- We may use this information to contact you about other of our own services that we believe may be of genuine interest to you, and for the purpose of important service communications;
- We will NOT use this data for any further purpose without your express further consent;
- We will NEVER sell your information to any 3rd parties without your permission.
We will only ask you for the minimum amount of information required to appropriately fulfil your request. This will usually be your name, one or more contact details, and any specific information about your request.
If we do not enter into a further contract or agreement with you, we will retain this data for a maximum of 12 months. If purchase one of our products or you otherwise choose to enter into an agreement with us, we will retain the data for the length of our ongoing agreement plus a maximum of 12 months.
Technical data (such as IP address)
Purpose & categories of data:
When you visit our website, our systems will log a record of your visit in our server logs, and typically this record will include the technical ‘IP’ address that is associated with your device and the browser type and version that you are using.
Such server logs are extremely common practice, and are used to monitor technical resources, monitor high-level server activity, and importantly to detect and prevent malicious or fraudulent activity on our systems. This data can also be used, if required, to diagnose reports of technical issues. The storage of IP addresses, allow us to identify patterns of behaviour (such as repeated malicious attempts to access a system).
IP addresses, in and of themselves, do not allow us in any way to identify you as an individual, especially given that it is very common for IP addresses to be dynamically allocated by your service provider, and will therefore often routinely change.
Furthermore, we do not and will not use the content of server access logs to attempt to determine an identifiable individual. We therefore do not consider that data held within server logs falls within the scope of ‘personal data’.
In the event that such anonymous data is considered to fall within the scope of the applicable data protection regulations, the legal basis for processing such data is:
Our Legitimate interest (GDPR Art 6(1)(f)): The integrity, security and performance of our systems and infrastructure is a vital part of the services that we offer. We consider that it is in our legitimate interest to maintain and protect our systems to this end.
Types of processing
- We will store the information you provide to us in our website server logs
- For the purpose of maintaining the integrity of our systems, we may also store this data in infrastructure backups
- We will NOT use this data to attempt to identify an individual person
Server logs are automatically rotated on our systems, and are retained for a maximum of 12 months following the closure of the relevant log file.
Cookies, Web Beacons & Similar technologies
Purpose & Categories of data:
Cookies, web beacons and other similar technologies allow us to better understand how users are using our website and other related services.
They are all essentially small data files placed on your computer (or other device) that allow us to tell when you have visited a particular page, or performed a particular action (such as clicking a particular button) on our website.
These technologies are used by most websites as they provide useful insight into how the services are being used, as well as improving speed, performance and security, and enabling us to improve our personalisation of your experience.
Cookies – Small text files placed in the memory of your browser or device when you visit a website. Cookies allow a website to recognize a particular device or browser.
There are a number of ways that you can influence how cookies are used on your particular device. Most commercial browsers (such as Chrome, Safari, Edge, Internet Explorer, Firefox etc) allow you to set preferences for whether to allow or block website cookies. They will also provide tools that allow you to remove any cookies that have already been set. Using the ‘Help’ functionality of your browser, or an internet search, will help you to understand how to use these features for your particular browser.
Web beacons – Small graphic images (also known as “pixel tags” or “clear GIFs”) that may be included on our sites and services that typically work in conjunction with cookies to identify our users and user behaviour.
Our uses of such technologies fall into the following general categories:
- Advertising or Targeting Related. We may use first-party or third-party cookies and web beacons to deliver content, including ads relevant to your interests, on our sites or on third party sites. This includes using technologies to understand the usefulness to you of the advertisements and content that have been delivered to you, such as whether you have clicked on an advertisement.
Our Legitimate interest (GDPR Art 6(1)(f)): Understanding the performance of our systems and the behaviour of visitors to our website helps us better to develop our products and services. We consider that it is in our legitimate commercial interest to maintain, develop and market our products in this way.
Access to your personal data
In the situation where you have directly provided personal information to us (such as by completing an online form or contacting us for further information), you have a number of rights regarding the personal data that we hold:
- You have the right to obtain from us confirmation about whether any such data is being held;
- You have the right to require that we provide you with whatever data we are holding/processing about you, including the right for that data to be transferred to another data controller;
- Even if you have consented to Us processing your personal data, you have the right to withdraw that permission at any time;
- You have the right to require us to rectify any incomplete or incorrect information held about you;
- You have the right to require us to erase the data held about you (the ‘right to be forgotten’);
In the situation where we collect personal data automatically (such as from your internet browser or via internet Cookies or other similar technologies):
- You have the right to object to the legal basis upon which we are collecting this data, and We have an obligation to consider and respond to that objection;
- You have the right to request the prevention of further processing of your data while your objection is considered;
- You have the right to make a complaint to the relevant data protection authority.