INFORMATION ON THE PROCESSING OF PERSONAL DATA
pursuant to Article 13 of the EU Regulation 2016/679 (General Data Protection Regulation or ‘GDPR’)
With this information, Fdm Overseas – Hong Kong LTD. (hereinafter referred to as “Fdm Overseas” or the “Controller”) intends to inform users and visitors of the website “www.fdmoverseas.com” (hereinafter the “Website”) about the policy adopted regarding the protection of personal data, emphasizing our commitment and attention to the privacy of Website visitors. Navigation within the Website is free and does not require any registration. This information is provided solely for the Website and not for other websites that the user may visit through links. XXX cannot be held responsible for personal data provided by users to external parties or to any websites linked to this Website. In accordance with the EU Regulation 2016/679, the Controller provides the following information.
1. Data Controller
The Data Controller is Fdm Overseas – Hong Kong LTD., VAT and tax code number, with registered office at Hong kong, 131 – 132 Connaught Road West, SAI YING PUN and phone: +85221084148.
2. Categories of Personal Data Processed
Connection and Navigation Data
The computer systems and software procedures used to operate the Website acquire certain personal data during their normal operation, the transmission of which is implicit in the use of Internet communication protocols. This category of data includes IP addresses or domain names of the computers and terminals used by users, the URI/URL (Uniform Resource Identifier/Locator) addresses of the requested resources, the time of the request, the method used to submit the request to the server, the size of the file obtained in response, the numerical code indicating the status of the response given by the server (successful, error, etc.), and other parameters related to the user’s operating system and computer environment. This data is collected solely for the purpose of obtaining anonymous statistical information about the use of the Website and to ensure its proper functioning. The data is deleted immediately after processing.
Data Communicated by the User
The optional, explicit, and voluntary sending of communications to the contact addresses of Fdm Overseas – Hong Kong LTD. provided on the Website involves the acquisition of the sender’s contact data, necessary to respond, as well as all personal data included in the communications.
Cookies
For more information on the use of cookies by Fdm Overseas – Hong Kong LTD., please read our Cookie Policy available in the footer of the pages of our Website.
3. Data Processing Methods
The processing of personal data concerning you will be carried out using electronic means, in accordance with methods and tools suitable to ensure the security and confidentiality of the data. In particular, all technical and organizational security measures will be adopted to guarantee an adequate level of data protection as required by law, allowing access only to authorized persons appointed by the Controller or by the persons in charge designated by the Controller. The information acquired and the processing methods will be relevant and not excessive in relation to the type of services provided.
4. Purposes and Legal Bases of the Processing
The processing carried out through the Website is performed for the following purposes and based on the following legal conditions:
a) to allow you to navigate on our Website, the acquisition of such data is automatic.
b) to respond to your request, providing the data is optional, however, in case of failure, partial, or inaccurate provision, we may not be able to fulfill, in whole or in part, your requests.
For this data processing, the legal basis of the processing is the performance of a contract and the execution of pre-contractual measures (Art. 6 para. 1 letter b) GDPR);
c) to protect our rights in legal proceedings. The legal basis for this processing is the necessity of pursuing our legitimate interests (Art. 6 para. 1 letter f) GDPR) (protection of our rights in legal proceedings).
5. Recipients of the Data
The personal data of users processed through the website may be communicated to the following categories of recipients:
(a) external providers and professionals to whom FDM OVERSEAS – HONG KONG LTD may turn for the maintenance, assistance, and technological update of the Website;
(b) all those subjects (including Public Authorities) who have access to personal data by virtue of regulatory or administrative measures;
A list of autonomous data controllers and data processors is available upon request at the contact details of the controller. Data processors are bound by appropriate contractual obligations to implement adequate security measures to protect the security and confidentiality of personal data.
Finally, the data may be used by the police and the judicial authorities for the detection of responsibilities in case of hypothetical computer crimes against the Website.
6. Period and Location of Personal Data Retention
Fdm Overseas – Hong Kong LTD. retains personal data for the purpose specified in point 5. (b) for the time necessary to respond to requests and, in any case, no later than six months from the closing of the conversation with the user, unless the requests lead to potential disputes. In such cases, the data will be kept based on the purpose specified in point 5(c) until the end of the disputes. The data collected for the purpose specified in point 5(c) will be retained for the time necessary to defend the rights of the Controller or for the time required by the judicial authority in case of investigation of potential crimes.
The personal data of users are stored through servers located within the European Economic Area for the time strictly necessary to achieve the aforementioned purposes, in compliance with civil and tax retention obligations and the limits set by law. However, the Controller reserves the right to use services located in non-EU countries (e.g., hosting of the website, Google Analytics service). In such cases, service providers are selected among those who provide adequate guarantees according to Articles 45 and following of the GDPR. User data collected through cookies are processed and retained according to the terms specified in the Cookie Policy.
7. Rights of Data Subjects
As a data subject, according to Articles 15 to 22 of the Regulation, you have the right to exercise the following rights:
Right of Access: You may request confirmation of whether or not your personal data is being processed and, if so, access to such data and specific information about the processing, such as, for example, the purposes, the categories of data being processed, and the existence of the other rights listed below. You may also request a copy of your data.
Right of Rectification: You have the right to request the correction of your personal data and/or the integration of incomplete personal data concerning you.
Right of Erasure: You may obtain the erasure of your data without undue delay if (i) such data is no longer necessary for the purposes for which it was collected, (ii) you have withdrawn your consent on which the processing was based (unless there is another legal basis for such processing), (iii) you object to the processing of your data (as specified below) and there are no overriding legitimate grounds for the processing, or if you object to the processing of your data for marketing purposes, (iv) your data is processed unlawfully, (v) your data must be erased to comply with a legal obligation. Please note that this right does not apply if the processing of the data is necessary, among other reasons: to comply with a legal obligation and for the establishment, exercise, or defense of legal claims.
Right to Restriction: You have the right to obtain the restriction of processing in the following cases:
– If you contest the accuracy of your personal data, for a period allowing the controller (Company) to verify the accuracy of the data;
– If the processing is unlawful, and you request the restriction of use instead of erasure of the data;
– If you need the data for the establishment, exercise, or defense of legal claims;
– If you have objected to the processing (as specified below), pending the verification of whether the legitimate grounds of the controller override your interests.
Right to Data Portability: You have the right to receive the personal data concerning you in a structured, commonly used, and machine-readable format and have the right to transmit those data to another data controller where the processing is based on consent or is necessary for the performance of a contract, and the processing is carried out by automated means. You also have the right to have the personal data transmitted directly from one data controller to another, where technically feasible. However, the right to data portability does not affect the right to erasure as specified above.
Right to Object: You have the right to object at any time to processing based on the legitimate interests of the controller, unless the controller demonstrates compelling legitimate grounds for the processing that override your interests, rights, and freedoms or for the establishment, exercise, or defense of legal claims.
The above rights can be exercised by making a request to the Controller, without formalities, through a letter or email to the contact details indicated in section 1.
Right to Lodge a Complaint: Furthermore, you have the right under Art. 77 of the Regulation to lodge a complaint with the Italian Data Protection Authority (www.garanteprivacy.it).
