Privacy Policy
Our Privacy Policy
The registered trademark owner of Cycnix® is Tongda Air Conditioning Products Co., Ltd. (hereinafter referred to as "Tongda", "the Company" and "we"). We adhere to a set of business principles and ethical conduct that help drive the company forward. One of the principles in this regard is respect for others and privacy, which starts with respecting and protecting the personal data obtained by Tongda. In order to protect the confidentiality of your personal data, we implement the following data privacy principles:
We respect your privacy and promise to protect your personal data.
We only collect personal data that we consider to be relevant and necessary to operate our business.
Unless you have been clearly informed or have obtained your consent or as required by law, Tongda will not disclose your personal information to the outside world.
We want to keep your personal data accurate and up-to-date.
We maintain appropriate security measures to prevent unauthorized access to your personal data.
Personal data monitoring
We have appointed a Data Protection Officer who is responsible for reviewing questions in relation to this Privacy Statement. If you have any questions about this Privacy Statement, including any requests to exercise your legal rights, please contact the Data Protection Officer using the details set out below.
Personal data supervisor: Mr. Lucas KK Law
Mailing Address: BLK N, 4/F, PHASE 1, Kwun Tong Industrial Centre, Kwun Tong, Kowloon, Hong Kong
Tel: +852 2344 1607
Email address: lkk@staterich.com
We only respond to data protection related inquiries. Please write in English or Chinese.
Regulatory agencies
You also have the right to lodge a complaint with the relevant regulatory authority at any time.
We collect personal information about you
Personal data is any information that can be used to identify an individual, but does not include data from which the identity has been removed (anonymous data).
We may collect, use, store and transfer various types of personal data that we have grouped together as follows:
Identification information includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth, and gender.
Contact information includes address, email address and phone number.
Technical Data includes Internet Protocol (IP) addresses, your login details, browser type and version, time zone setting and location, browser plug-in type and version, operating system and platform, and other technology on the devices you use to connect to this website.
Usage data includes information about how you use our website.
Marketing and Communications Information includes your preferences in receiving marketing communications from us and third parties and your communications preferences.
We do not collect or process any Special Categories of Personal Data about you (this includes but is not limited to information about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership and information about your health, genetic and biometric data). We also do not collect any criminal convictions and offences data.
How do we collect your personal data?
We collect your personal data using the following different methods:
Direct Interactions. You may give us your identity, contact details and marketing and communications information by filling in forms or by post, telephone, email or other means.
Automated technologies or interactions. When you interact on our website, we may automatically collect technical information about your device, browsing actions and browsing patterns. We collect this personal information by using cookies, server logs and other similar technologies. Please see our cookie policy for more details.
Third Parties. We may receive your personal data from various third parties, as follows:
Analytical data from:
Adobe Analytics, headquartered in Ireland
Content Square, headquartered in France
Technical monitoring proposals from:
New Relic, headquartered in the United States
Map services from:
Google Maps, headquartered in the United States
Baidu Maps, headquartered in China
Purposes for which we use your personal data
We have described below in a table format all the ways we plan to use your personal data. We have also identified our legal rights where applicable.
Please note that we may rely on more than one legal basis to process your personal data, depending on the purpose for which we are using your data. Please contact us where we rely on more than one legal basis to process your personal data in the table below and you need specific details about each legal basis.
Purpose/Activity/Notify you of changes to our Privacy Statement
Data Type/ (a) Identity (b) Contact (c) Marketing and Communications
Legal basis for processing, including legitimate interests: (a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (to update our records)
Retention period / 12 months
Purpose/Activity/ To administer and secure our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and data loading)
Data Type/ (a) Identity (b) Contact (c) Technology
Legal basis for processing, including legitimate interests (a) Necessary for our legitimate interests (for running our business, provision of administrative and IT services, network security, fraud prevention and business restructuring or group reorganisation activities) (b) Necessary to comply with a legal obligation
Retention period / 12 months
Purpose/Activity/ Use data analytics to improve our website, products/services, marketing, customer relationships and experience
Data Category/ (a) Technology (b) Usage
The legal basis for the processing, including the basis of legitimate interests / Necessary for our legitimate interests (to clearly categorise the types of customers who use our goods and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
Retention period / 25 months
Purpose/Activity/ To provide you with marketing communications and information about our company and products
Data Type/ (a) Identity (b) Contact (c) Marketing and Communications
Legal basis for processing, including basis of legitimate interest/ (a) Necessary for our legitimate interests (to develop our products/services and grow our business) (b) Consent
Retention period / until the data subject has been notified that he or she no longer wishes to receive marketing communications
Purpose/Activity/ We will reply you directly after you contact us
Data Type/ (a) Identity (b) Contact (c) Contact Person, Marketing and Communications
Legal basis for processing, including basis of legitimate interest/ (a) Necessary for our legitimate interests (to respond to your request) (b) Consent
Retention period/ 48 months after last contact
Change of use
We will only use your personal data for the purpose for which it was collected, unless we consider that it is reasonably necessary to use it for another purpose and that purpose is compatible with the original purpose. If you want to understand how the processing for a new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and explain to you the legal basis which allows us to take such action.
Please note that we may process your personal data without your knowledge or consent where this is required or permitted by law.
Data Retention
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes for which we collected it, including to comply with any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for longer periods of time if there is a complaint or if we have reasonable grounds to believe that there is a risk of litigation in relation to our relationship with you.
To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
The table above sets out details of the retention periods for different aspects of your personal data.
Marketing
You can ask us or third parties to stop sending you marketing information at any time by clicking on the opt-out link we send you or by contacting us.
You may opt-out of receiving these marketing communications, but this will not apply to personal data provided to us for activities/purposes 1-4 above.
Disclosure of your personal information
Based on your consent, we may share your personal data with internal and external third parties.
In any case, we require all third parties to keep your personal data secure and to process it in accordance with applicable laws. We do not allow our third-party service providers to use your personal data for their own purposes and only allow them to process your personal data for specific purposes as instructed by us.
Data Security
We have put in place appropriate security measures to prevent your personal data from accidental loss, unauthorised use or access, alteration or disclosure. In addition, we limit access to your personal data to those employees, agents and other third parties who have a business need to know. They will only process your personal data on our instructions and are obliged to keep it confidential.
We have put in place procedures to deal with any suspected personal data breach and will report any relevant breach to you and any appropriate regulator where required by law.
Cookies
In order to enhance the functionality of this website and facilitate your browsing, some web pages have "Cookies". This plain text file is placed in your computer's web browser to store your personal preferences. "Cookies" themselves will not disclose your email address or other personal information to us unless you choose to provide this information directly to this website. But when you choose to provide your personal information to the website, this information will be linked to the information stored in "Cookies". Most web browsers are initially set to accept "Cookies". You can set your web browser to reject "Cookies" yourself, or set your web browser to notify you when accepting "Cookies". However, if you choose to reject "Cookies", some functions of this website may not work.
For more information on our Cookies policy, please click on the link.
Your legal rights
Under certain circumstances, you may have the following rights under data protection legislation in relation to your personal data:
Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to verify that we are lawfully processing it.
Request correction of the personal data we hold about you. This enables you to have any incomplete or inaccurate data held about you amended, but we may need to verify the accuracy of the new information you provide to us.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove personal data where you have exercised your right to object to processing (see below), because we may have processed your data unlawfully or where erasure is required to comply with local law. Please note, however, that we may not be able to comply with all of your erasure requests for specific legal reasons which we will notify you of at the time of your request (if applicable).
Object to processing of your personal data. Where we rely on a legitimate interest (or the interests of a third party) and you object to processing on this basis for specific reasons as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we process your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your data which override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us to suspend processing of your personal data in the following circumstances:
If you ask us to confirm the accuracy of the data.
It's unlawful for us to use the data but you don't want us to delete it.
You need us to hold information even if we no longer require it because you require it to establish, exercise or defend your rights in legal proceedings.
You object to our use of your information but we need to make sure we have overriding legal grounds to use the information.
Request the transfer of your personal data to a third party. When we provide your personal data to you or a third party you have chosen, we will use it in a structured, commonly used and machine-readable format. Please note that this right only applies to automated data which you initially consented to us using or where we used the data to perform a contract with you.
Withdraw your consent at any time. Where we rely on your consent to process your personal data, you may withdraw your consent at any time. However, the lawfulness of any processing carried out before your withdrawal of consent will not be affected. If you withdraw your consent, we may not be able to provide you with certain goods or services. We will notify you if this happens when you withdraw your consent.
If you wish to exercise any of the above rights, please contact the Data Supervisor.
No fees are charged under normal circumstances
You do not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse your request in these circumstances.
Information We May Request
We may need to ask you for specific information to help us verify your identity and ensure you are entitled 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 for further information so that we can respond to you as quickly as possible.
Time limit for reply
We try to respond to all legitimate requests within one month. If your request is particularly complex or you have made multiple requests, it may take us longer than a month to process you. In this case, we will notify you and provide you with updates.
Your duty to notify us of changes to your data
It is important to us that we keep accurate and up-to-date information about you. Please notify us promptly if your personal information changes during your relationship with us.
Contact Tongda
If you have any questions about this policy, privacy practices or general contact information, please contact us in writing or by phone:
STATE RICH AIR CONDITIONING PRODUCTS LIMITED
BLK N, 4/F, PHASE 1,
Kwun Tong Industrial Centre
Kwun Tong, Kowloon, Hong Kong
+852 2344 1607
Email address: lkk@staterich.com.hk
We only respond to data protection related inquiries. Please write in English or Chinese.
Enquiries: info@staterich.com.hk
We only respond to inquiries related to after-sales service. Please write in English or Chinese.
Personal data supervisor: Mr. Lucas KK Law
This policy was updated in August 2024