1. Introduction
Airwin Group HK Limited respects your privacy and is committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data when you visit www.ciarraappliances.com (referred to as “our website” or “the website” in this privacy policy) (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.
2. Who we are and other important information
2.1 Who we are
Airwin Group HK Limited, a limited liability company incorporated under the laws of Hong Kong (collectively referred to as “Airwin”, “we”, “us” or “our” in this privacy policy), is the controller and responsible for your personal data.
2.2 Our EU representative
For users located in the EEA, as we are not established in the European Economic Area (“EEA”), we have designated Veyma Trading GmbH as our representative in the EEA pursuant to Article 27 of the GDPR. You may contact our EU representative at cs-eu@ciarraappliances.com.
2.3 Purpose of this privacy policy
This privacy policy aims to give you information on how Airwin collects and processes your personal data through your use of this website, including any data you may provide through this website when you purchase a product or service.
This website is not intended for children and we do not knowingly collect data relating to children.
It is important that you read this privacy policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements other notices and privacy policies and is not intended to override them.
2.4 Changes to the privacy policy
We keep our privacy policy under regular review and place any updates on our website.
2.5 Third-party links
This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect, use or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.
3. The data we collect about you
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
3.1 We may collect, use, store and transfer different kinds of personal data for order processing and fulfilment.
|
Processing Purpose |
Personal Data Categories |
Legal Basis |
|
To create user accounts |
User name, selected country, email address |
Performance of a contract |
|
To process and manage orders |
User name, selected country, email address, shipping name, shipping address, shipping phone number, billing name, billing address, billing phone number |
Performance of a contract |
|
To arrange shipment and deliver products |
Shipping name, shipping address, shipping phone number |
Performance of a contract |
|
To maintain billing, invoice and transaction records |
Billing name, billing address, billing phone number |
Performance of a contract; compliance with a legal obligation |
|
To provide after-sales support, including returns, exchanges and refunds, and communicate with customers regarding orders and related services |
User name, selected country, email address, shipping name, shipping address, shipping phone number, billing name, billing address, billing phone number |
Performance of a contract |
We may also put your personal data into aggregated and anonymized form. Once anonymized, that data is no longer your personal data. However, if we combine or connect that anonymized, aggregated data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.
3.2 Special categories of personal data
Certain categories of personal data, such as details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data, is special categories of data requiring additional protection under applicable data protection laws and is referred to here as “Special Categories of Personal Data”. We do not, via the website, collect any Special Categories of Personal Data about you. Nor do we collect any information about criminal convictions and offences.
3.3 If you fail to provide personal data
Where we need to collect personal data by law, or to perform a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel the contract you have with us, but we will notify you if this is the case at the time.
4. How is your personal data collected and processed?
For the abovementioned processing purposes, we will collect your personal data either independently or through third parties via web pages, Cookies, and similar device identification technologies, as well as other tools, facilities, or equipment. You can manage or delete Cookies through your browser or device settings; please note that if you disable Cookies, some features may not function properly.
If you provide us with personal data of others, you must ensure that you have obtained separate consent from those individuals for such provision. Otherwise, if our use of the provided information infringes upon their personal data rights, we reserve the right to pursue legal liability against you in accordance with relevant laws and regulations.
5. Cookies
Cookies are text files placed on your computer to collect standard Internet log information and visitor behavior information. When you visit our website, we may collect information from you automatically through cookies or similar technology. You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use and how we use them, please see our Cookie Policy .
6. your personal data
We may share your personal data with the parties set out below for the purposes set out in this policy.
(a) IT service providers, providing system administration, hosting and support services;
(b) Third party customer support services;
(c) Our delivery partners;
(d) Professional advisers including lawyers, auditors and insurers who provide consultancy, legal, insurance and accounting services; and
(e) Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets, in which case your personal data held by us will be one of the transferred or merged assets. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy;
We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy. We have contracts in place with the third parties and require them to treat your personal data lawfully and permit them to only process your personal data for specified purposes and in accordance with our instructions.
7. International Transfer of Data
We may store your personal data on a local server or a server located in a foreign country depending upon our and service providers’ IT configurations, which may be adjusted in order to comply with data protection requirements and satisfy our business needs and order fulfillment obligations. If your personal data is stored on a server in a foreign country, we will take organizational and technical measures to keep your data secure and give your data a level of protection which is comparable to the level of protection required by the law of the country where you are from.
For the purposes described in this Policy and to support our order processing and fulfillment activities, your personal data may also be accessed by our affiliates in China. Such access involves a cross-border transfer of personal data.
Specifically, for users from the EEA, your personal data collected by us may be stored on servers located in the EEA, the United States or China. Transfers of personal data out of the EEA, including storage on the servers located outside the EEA and access by our affiliates in China, are carried out on the basis of the European Commission’s Standard Contractual Clauses for data subjects located in the EEA. We have implemented appropriate safeguards to give your data a level of protection which is comparable to the level of protection required within the EEA. You may contact us to obtain a copy of the SCCs, subject to necessary redactions, or further information on the transfer safeguards.
8. Data retention
Personal data collected and processed for order processing and fulfillment purposes, including order management, shipment and delivery and after-sales support, will be retained for the duration of the relevant order relationship and for 3 years after completion of the relevant order and related services, unless a longer retention period is required by applicable law or necessary for the establishment, exercise or defence of legal claims.
Personal data collected and processed for billing and invoicing purposes will be retained for the duration of the relevant order relationship and for up to 10 years thereafter, as required by applicable tax, accounting and commercial record-keeping laws, unless a longer retention period is required by applicable law or necessary for the establishment, exercise or defence of legal claims.
9. Your legal rights
9.1 Under certain circumstances, you have rights under applicable data protection laws in relation to your personal data to:
(a) Request access to your personal data. This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
(b) Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
(c) Request erasure of your personal data. This enables you to ask us to delete or remove personal data in certain circumstances.
(d) Object to processing of your personal data where the data processing is based on your consent or our legitimate interest or that of a third party. In this case, we may demonstrate that we have compelling legitimate grounds which override your interests or we require your data to assert, exercise or defend against legal claims.
(e) Object to processing your personal data for direct marketing purposes.
(f) Request restriction of processing of your personal data in certain circumstances.
(g) Request the transfer of your personal data to you or to a third party. We will provide – where technically possible - to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Please note that this right only applies to automated information which you initially provided consent for us to use or where the information is necessary for us to perform a contract with you.
(h) Withdraw consent at any time where we are relying on consent to process your personal data.
(i) Make a complaint to the competent supervisory authority if you believe that the processing of your personal data violates legal requirements. We would, however, appreciate the chance to deal with your concerns before you approach the supervisory authority so please contact us in the first instance.
(j) Post-mortem right: where French data protection law applies, you may define instructions regarding the retention, deletion and communication of your personal data after death, and may designate a person to carry out such instructions; in the absence of such designation, your heirs may exercise certain rights in relation to your personal data for specified purposes, in accordance with applicable French data protection law.
If you wish to exercise any of the rights set out above, please contact us at cs-eu@ciarraappliances.com. For users located in the EEA, you may also contact our EU representative at cs-eu@ciarraappliances.com
9.2 What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
10. Children’s Data
This website is not intended for children and we do not knowingly collect children’s data. If parents or legal guardians suspect that their children have provided us with personal data inadvertently, they may request such personal data be removed by contacting us at cs-eu@ciarraappliances.com. For users located in the EEA, they may also contact our EU representative at cs-eu@ciarraappliances.com.
11. Data security
We have put in place appropriate security measures such as encryption technologies and authentication systems in line with the current state of the art to protection and maintain the security of your personal data.
100% security and protection in the case of transmission of data via the Internet cannot be guaranteed, but we make our best efforts to prevent your personal data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
12. Contact us
If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact us at cs-eu@ciarraappliances.com. For users located in the EEA, you may also contact our EU representative at cs-eu@ciarraappliances.com.
