Privacy Policy

Who we are and what this statement covers

[LEGAL_ENTITY_NAME] (“we”, “us”, “Golden Field”) operates this website and provides agroconsulting, agrotrading and AgriTech services from Room 602, 6/F, Kai Yu Commercial Building, 2C Argyle Street, Mong Kok, Kowloon, Hong Kong. In respect of the personal data described below we act as a data user within the meaning of the Personal Data (Privacy) Ordinance (Cap. 486) of Hong Kong (the “PDPO”), and we observe the six Data Protection Principles set out in Schedule 1 to the PDPO. This statement covers personal data collected through this website and through the business correspondence that arises from it. Personal data exchanged under a signed services or supply contract is additionally governed by the terms of that contract.

Personal data we collect

We collect only personal data that is necessary for, and directly related to, our business, and we collect it by lawful and fair means (DPP1). Providing your data is voluntary. If you choose not to provide it, we may be unable to answer your enquiry or supply the service you have asked for.

• Identity and contact details you submit through the forms on this website: name, email address, telephone number, company, position, subject and the content of your message.
• Correspondence: the emails, calls and messages you exchange with us, and the records we keep of them.
• Commercial details you provide when you request a quotation or a specification, such as the commodity, volume, delivery basis and destination you are interested in.
• Technical data recorded automatically by our hosting infrastructure when a page is served, such as IP address, browser type, referring page and time of request.
• Your language preference, stored in a cookie so that the site opens in the language you selected.

How we use personal data

We use personal data only for the purpose for which it was collected or for a directly related purpose, unless you give your express and voluntary consent to another use (DPP3).

• Answering your enquiries and providing the quotations, specifications and price information you requested.
• Negotiating, concluding and performing services and supply contracts, including logistics, documentation and payment administration.
• Maintaining our client and counterparty records and the internal administration of our business.
• Improving the content and usability of this website.
• Complying with applicable law and with requests from courts, regulators and other competent authorities.
• Direct marketing, but only on the basis described in the next section.

Direct marketing

Part VIA of the PDPO governs any use of personal data in direct marketing. We will not use your name, email address or telephone number to send you market updates, service announcements or other promotional material unless we have first told you which data will be used and for which classes of goods and services, and you have given your consent or indicated that you do not object. You may withdraw that consent at any time and free of charge, by replying “unsubscribe” to any message we send or by writing to info@gfhk.hk, and we will stop using your data for direct marketing once we act on your request. We do not sell, rent or otherwise provide personal data to any third party for that third party’s own direct marketing.

Who we may share personal data with

We do not sell personal data. We disclose it only where that is necessary for a purpose described above, and we require anyone who handles it for us to keep it secure and to use it only on our instructions (DPP2(3) and DPP4(2)). Personal data may be disclosed to the following classes of transferee:

• Our own directors and staff who need it in order to carry out their duties.
• Service providers acting for us under contract, such as website hosting, email, IT support and document storage providers.
• Professional advisers, including lawyers, auditors and insurers, where they need it in order to advise us.
• Counterparties, carriers, inspection companies, banks and customs authorities, where disclosure is necessary to perform a contract you are party to or have asked us to arrange.
• Courts, regulators, law enforcement and other authorities, where we are required or permitted by law to disclose.

Transfers outside Hong Kong

Our business is international, and personal data may be transferred to, or accessed from, places outside Hong Kong — for example where a counterparty, a carrier or a service provider is located abroad. Section 33 of the PDPO, which would restrict transfers of personal data outside Hong Kong, has been enacted but has not been brought into operation, so it does not at present impose a statutory restriction on such transfers. We nevertheless take the standard it sets as our own practice: we transfer personal data outside Hong Kong only where that is necessary for a purpose described in this statement, and we place the recipient under contractual obligations to protect the data to a standard comparable with the PDPO.

Keeping personal data secure

We take steps that are reasonably practicable to protect personal data against unauthorised or accidental access, processing, erasure, loss or use (DPP4). This website is served over an encrypted HTTPS connection. Access to personal data within our organisation is limited to those who need it for their work, and everyone with access is bound by a duty of confidentiality. No transmission over the internet can be guaranteed to be completely secure; if you need to send us commercially sensitive information, please agree a secure channel with us first.

Accuracy and how long we keep data

We take reasonably practicable steps to keep personal data accurate and up to date (DPP2(1)), and we ask you to tell us when your details change. Personal data is erased once it is no longer required for the purpose for which it is used (DPP2(2)). In practice we keep enquiry and correspondence records for [DATA_RETENTION_PERIOD], and contract, accounting and shipping records for as long as the applicable retention obligations of Hong Kong law require, after which they are securely deleted or anonymised.

Your rights: data access and data correction requests

The PDPO gives you specific rights over your own personal data. To exercise them, write to info@gfhk.hk or to our Hong Kong address below. We may need to verify your identity before we act on a request.

• Data access request — you may ask whether we hold personal data about you and, if we do, ask for a copy of it (sections 18 and 19 of the PDPO). We will respond within 40 days. We may charge a fee that is not excessive for complying with the request.
• Data correction request — if you believe that personal data we hold about you is inaccurate, you may ask us to correct it (section 22 of the PDPO). We will respond within 40 days.
• Withdrawal of consent — you may withdraw your consent to direct marketing at any time and free of charge, and you may withdraw consent to any other use of your data that relies on consent, without affecting the lawfulness of what we did before the withdrawal.
• Please note that Hong Kong law does not confer the rights to data portability, to restriction of processing, or to general erasure that exist under the EU General Data Protection Regulation. Requests of that kind are not statutory rights under the PDPO, but we will consider them on their merits and tell you what we are able to do.

Questions and complaints

If you are not satisfied with the way we have handled your personal data or your request, please contact us first so that we can try to resolve the matter. You also have the right to complain to the Office of the Privacy Commissioner for Personal Data, Hong Kong, which supervises compliance with the PDPO.