ARCPROLED LIMITED PRIVACY POLICY
Last update: 01.12.2019
This Privacy Policy governs what we can and cannot do with the information that you provide.
ARCPROLED Limited and its related companies are committed to protect your privacy. This Privacy Policy applies across all websites that ARCPROLED Limited owns and all services we are offering.
This Privacy Policy governs our data collection, processing and usage practices. It also describes your choices regarding use, access and correction of your personal information. If you do not agree with the data practices described in this Privacy Policy, you should not use our services.
Personal data means any information relating to an identified or identifiable natural person. An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
As the Data Controller, we have implemented numerous technical and organizational measures to ensure the most complete protection of personal data processed through this website. However, Internet-based data transmissions may in principle have security gaps, so absolute protection may not be guaranteed. For this reason, every data subject is free to transfer personal data to us via alternative means, e.g. by telephone.
This Privacy Policy may have to be updated from time to time and we will post any Privacy Policy changes on this page.
Who we are
‚We’ are ARCPROLED Limited and our wholly-owned subsidiaries (if any). We provide lighting products and control system as well as we offer OEM and ODM services for our clients.
More information about us can be found at our About page on this website.
For European Union data protection purposes, when we act as a controller in relation to your personal data, our Data Protection Officer is our representative and can be contacted at privacy@arcproled.com
How we collect information
When you visit our websites or use our services, we collect personal data. We will only use and disclose such personal data as described in this Privacy Policy.
Information you provide to us directly
When you visit or use some parts of our website and/ or services we might ask you to provide personal data to us. For example, we ask for your contact information when you sign up for our Newsletter, use our contact form, respond to an email offer, use our password protected service areas or join us on social media.
If you do not want to provide us with personal information, you do not have to, but this might mean that you cannot use some parts of our website or services.
Information we collect automatically
While you use our site and services, we collect general information of the sort that web browsers, servers and network operators typically make available. These include things like your IP address and device type. We also collect information what you navigate through our website and use our services, including what pages you looked at and what links you clicked on. This information helps us troubleshoot problems, understand how you use our site, make improvements and ensure that we continue to provide the best possible experience.
Information we get from third parties
The majority of information we collect, we collect directly from you. Sometimes we might collect personal data about you from other sources, sich as publicly available materials or trusted third parties like our marketing partners. We use this information to supplement the personal data we already hold about you, in order to better inform, personalize and improve our services, and validate the personal data you provide.
Legal basis for the processing
Art. 6(1) lit. a GDPR serves as the legal basis for processing operations for which we obtain consent for a specific processing purpose. If the processing of personal data is necessary for the performance of a contract to which the data subject is party, as is the case, for example, when processing operations are necessary for the supply of goods or to provide any other service, the processing is based on Article 6(1) lit. b GDPR. The same applies to such processing operations which are necessary for carrying out pre-contractual measures, for example in the case of inquiries concerning our products or services. Is our company subject to a legal obligation by which processing of personal data is required, such as for the fulfillment of tax obligations, the processing is based on Art. 6(1) lit. c GDPR. In rare cases, the processing of personal data may be necessary to protect the vital interests of the data subject or of another natural person. This would be the case, for example, if a visitor were injured in our company and his name, age, health insurance data or other vital information would have to be passed on to a doctor, hospital or other third party. Then the processing would be based on Art. 6(1) lit. d GDPR. Finally, processing operations could be based on Article 6(1) lit. f GDPR. This legal basis is used for processing operations which are not covered by any of the above mentioned legal grounds, if processing is necessary for the purposes of the legitimate interests pursued by our company or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data. Such processing operations are particularly permissible because they have been specifically mentioned by the European legislator. He considered that a legitimate interest could be assumed if the data subject is a client of the controller (Recital 47 Sentence 2 GDPR).
How we use the information we collect
We may use the information we collect for some or all of the following purposes:
Provide you with news and information about our products
establish, maintain and administer your account
Maintain, troubleshoot and improve our site and services
If your preferences permit, to provide you with recommendations and personalized produdcts
Measure performance of our site and services
Secure and protect you, us, our platform and services
Communicate with you about our site and services – such as to notify of changes and updates, alert you to data or security breaches, and to provide you with customer support.
With your explicit consent, to create or distribute promotional and marketing material
In the case of non-personally identifiable information only – or personal information only with your explicit consent – to promoted and market ourselves, our products and services, and our websites (including any social media pages maintained or operated by us such as Facebook, Instagram, Twitter, YouTube etc); and
Any other uses identified to you at the time of collecting your personal information or as reasonably contemplated by this Privacy Policy.
How we share information we collect
Personal Information we collect stays within ARCPROLED Limited, other than in the following circumstances:
- When you give us explicit consent to share your data
- When we share it with the greater ARCPROLED family (i.e. with our affiliated companies) to provide better products and services to you
- When we share it with trusted external service providers and data processors such as data centers, web hosts, clod storage and cloud software providers, payment processors, debt collectors, accountants, and insurers
- When we share with prospective sellers or buyers of our business or assets
- When we share it with regulators and other relevant parties for the purpose of legal or contractual compliance, reporting purposes, or when we believe in good faith that disclosure is reasonable necessary to protect our property or rights, or the rights of third parties or the public at large.
Your rights
With your personal data you have certain rights relating to it. You may unsubscribe from our marketing communication by following the unsubscribe instructions located on the bottom of our emails or by emailing us at unsubscribe@arcproled.com or privacy@arcproled.com
Right of access:
- Know what personal data we hold about you, and to make sure it’s correct and up to date
- Request a copy of your personal data, or ask us to restrict processing your personal data or delete it
- Object to our continued processing of your personal data
You can exercise these rights at any time by sending an email to privacy@arcproled.com and we will respond to your within a reasonable period after the request is made.
We do not typically charge a fee for reasonable requests for access to your personal information. However, we may charge a reasonable fee, wich will be notified to you before we move forward with the request, for the time and cost if an extended amount of time is required to collate and prepare materials for you.
If you are not with how we are processing your personal data, please let us know by sending an email to privacy@arcproled.com . We will review and investigate your complaint, and try to get back you you within a reasonable time frame.
Retention
The length of time we keep your personal data depends on what it is and whether we have an ongoing business need to retain it (for example, to provide you with information you have requested or to comply with applicable legal, tax or accounting requirements).
We will retain your personal data for as long as we have a relationship with you and for a period of time afterwards where we have an ongoing business need to retain it, in accordance with our data retention policies and practices.
International Transfer of Information
Your information may be processed outside of the country where you live. For individuals in the European Economic Area (EEA), this means that your data may be transferred outside of the EEA. Regardless of where we use, process, or store your data, we will comply with the protections set out in this Privacy Policy. Where we disclose personal data to a third party in another country, we put safeguards in place to ensure your personal data remains protected.
Cookies
To make this site work properly, we sometimes place small data files called cookies on your device. Most big websites do this too. A cookie is a small text file that a website stores on a visitor’s computer, and that the visitor’s browser provides to the website each time the visitor returns. It enables the website to remember your actions and preferences (such as login, language, font size and other display preferences) over a period of time, so you don’t have to keep re-entering them whenever you come back to the site or browse from one page to another.
Our site uses cookies to help us identify you from other users, track your usage of our site, and your website access preferences. We do or may use the following cookies:
- Strictly necessary cookies. These are cookies that are required for the operation of our site. They include, for example, cookies that enable you to log into secure areas of our site, use a shopping cart or make use of e-billing services.
- Analytical/performance cookies. They allow us to recognize and count the number of visitors and to see how visitors move around our site when they are using it. This helps us to improve the way our site works, for example, by ensuring that users are finding what they are looking for easily.
- Functionality cookies. These are used to recognize you when you return to our site. This enables us to personalize our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
- Targeting cookies. These cookies record your visit to our site, the pages you have visited and the links you have followed. We will use this information to make our site and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.
Please note that third parties (including, for example, advertising networks and providers of external services like web traffic analysis services) may also use cookies, over which we have no control. These cookies are likely to be analytical/performance cookies or targeting cookies.
You can control and/or delete cookies as you wish – for details, see our cookie policy. You can delete all cookies that are already on your computer and you can set most browsers to prevent them from being placed. If you do this, however, you may have to manually adjust some preferences every time you visit a site and some functionalities may not work.
Business transfer
If we, or substantially all of our assets, were acquired, or in the event that we go out of business or enter bankruptcy, user information would be one of the assets that is transferred or acquired by a third party. You acknowledge and agree that if such transfers occur, that any acquirer of our business may continue to use your personal information as set forth in this Privacy Policy.
Links to third party websites
Our site may contain links to and from third party websites. If you click on such links, you do so at your own risk and subject to whatever privacy policy and/or website terms may govern the use of such websites. We have no control over, and are not responsible, nor liable for, the content, privacy practices or website terms of such websites or any information you provide to them. You should read the privacy policy of these third parties to find out how they handle your personal information when you visit their websites.
Existence of automated decision-making
As a responsible company, we do not use automatic decision-making or profiling.
How to contact us
If you have any questions or feedback about this Privacy Policy or our services, please do get in touch with us via email at privacy@arcproled.com or by fax or in written at:
ARCPROLED Limited
Unit 1203, 12/F, Hua Fu Commercial Building
111 Queen’s Road West, Sheung Wan
HONG KONG
Tel: +852 35869661
Fax: +852 35869662
Additional information of use third party services
Newsletter-Tracking
Newsletters of ARCPROLED Limited contain so-called tracking pixels. A tracking pixel is a miniature graphic embedded in such e-mails, which are sent in HTML format to enable log file recording and analysis. This allows a statistical analysis of the success or failure of online marketing campaigns. Based on the embedded tracking pixel, ARCPROLED Limited may see if and when an e-mail was opened by a data subject, and which links in the e-mail were called up by data subjects.
Such personal data collected in the tracking pixels contained in the newsletters are stored and analyzed by the controller in order to optimize the shipping of the newsletter, as well as to adapt the content of future newsletters even better to the interests of the data subject.
The marketing service provider for ARCPROLED Limited is Sendgrid what is an online marketing platform operated by TWILIO Inc.
Further information and the applicable data protection provisions of Sendgrid may be retrieved under: https://sendgrid.com/policies/privacy/
Data protection provisions about the application and use of Facebook
On this website, the controller has integrated components of the enterprise Facebook. Facebook is a social network.
A social network is a place for social meetings on the Internet, an online community, which usually allows users to communicate with each other and interact in a virtual space. A social network may serve as a platform for the exchange of opinions and experiences, or enable the Internet community to provide personal or business-related information. Facebook allows social network users to include the creation of private profiles, upload photos, and network through friend requests.
The operating company of Facebook is Facebook, Inc., 1 Hacker Way, Menlo Park, CA 94025, United States. If a person lives outside of the United States or Canada, the controller is the Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland.
With each call-up to one of the individual pages of this Internet website, which is operated by the controller and into which a Facebook component (Facebook plug-ins) was integrated, the web browser on the information technology system of the data subject is automatically prompted to download display of the corresponding Facebook component from Facebook through the Facebook component. An overview of all the Facebook Plug-ins may be accessed under https://developers.facebook.com/docs/plugins/. During the course of this technical procedure, Facebook is made aware of what specific sub-site of our website was visited by the data subject.
If the data subject is logged in at the same time on Facebook, Facebook detects with every call-up to our website by the data subject—and for the entire duration of their stay on our Internet site—which specific sub-site of our Internet page was visited by the data subject. This information is collected through the Facebook component and associated with the respective Facebook account of the data subject. If the data subject clicks on one of the Facebook buttons integrated into our website, e.g. the “Like” button, or if the data subject submits a comment, then Facebook matches this information with the personal Facebook user account of the data subject and stores the personal data.
Facebook always receives, through the Facebook component, information about a visit to our website by the data subject, whenever the data subject is logged in at the same time on Facebook during the time of the call-up to our website. This occurs regardless of whether the data subject clicks on the Facebook component or not. If such a transmission of information to Facebook is not desirable for the data subject, then he or she may prevent this by logging off from their Facebook account before a call-up to our website is made.
The data protection guideline published by Facebook, which is available at https://facebook.com/about/privacy/, provides information about the collection, processing and use of personal data by Facebook. In addition, it is explained there what setting options Facebook offers to protect the privacy of the data subject. In addition, different configuration options are made available to allow the elimination of data transmission to Facebook. These applications may be used by the data subject to eliminate a data transmission to Facebook.
Data protection provisions about the application and use of Google Analytics (with anonymization function)
On this website, the controller has integrated the component of Google Analytics (with the anonymizer function). Google Analytics is a web analytics service. Web analytics is the collection, gathering, and analysis of data about the behavior of visitors to websites. A web analysis service collects, inter alia, data about the website from which a person has come (the so-called referrer), which sub-pages were visited, or how often and for what duration a sub-page was viewed. Web analytics are mainly used for the optimization of a website and in order to carry out a cost-benefit analysis of Internet advertising.
The operator of the Google Analytics component is Google Inc., 1600 Amphitheatre Pkwy, Mountain View, CA 94043-1351, United States.
For the web analytics through Google Analytics the controller uses the application “_gat. _anonymizeIp”. By means of this application the IP address of the Internet connection of the data subject is abridged by Google and anonymised when accessing our websites from a Member State of the European Union or another Contracting State to the Agreement on the European Economic Area.
The purpose of the Google Analytics component is to analyze the traffic on our website. Google uses the collected data and information, inter alia, to evaluate the use of our website and to provide online reports, which show the activities on our websites, and to provide other services concerning the use of our Internet site for us.
Google Analytics places a cookie on the information technology system of the data subject. The definition of cookies is explained above. With the setting of the cookie, Google is enabled to analyze the use of our website. With each call-up to one of the individual pages of this Internet site, which is operated by the controller and into which a Google Analytics component was integrated, the Internet browser on the information technology system of the data subject will automatically submit data through the Google Analytics component for the purpose of online advertising and the settlement of commissions to Google. During the course of this technical procedure, the enterprise Google gains knowledge of personal information, such as the IP address of the data subject, which serves Google, inter alia, to understand the origin of visitors and clicks, and subsequently create commission settlements.
The cookie is used to store personal information, such as the access time, the location from which the access was made, and the frequency of visits of our website by the data subject. With each visit to our Internet site, such personal data, including the IP address of the Internet access used by the data subject, will be transmitted to Google in the United States of America. These personal data are stored by Google in the United States of America. Google may pass these personal data collected through the technical procedure to third parties.
The data subject may, as stated above, prevent the setting of cookies through our website at any time by means of a corresponding adjustment of the web browser used and thus permanently deny the setting of cookies. Such an adjustment to the Internet browser used would also prevent Google Analytics from setting a cookie on the information technology system of the data subject. In addition, cookies already in use by Google Analytics may be deleted at any time via a web browser or other software programs.
In addition, the data subject has the possibility of objecting to a collection of data that are generated by Google Analytics, which is related to the use of this website, as well as the processing of this data by Google and the chance to preclude any such. For this purpose, the data subject must download a browser add-on under the link https://tools.google.com/dlpage/gaoptout and install it. This browser add-on tells Google Analytics through a JavaScript, that any data and information about the visits of Internet pages may not be transmitted to Google Analytics. The installation of the browser add-ons is considered an objection by Google. If the information technology system of the data subject is later deleted, formatted, or newly installed, then the data subject must reinstall the browser add-ons to disable Google Analytics. If the browser add-on was uninstalled by the data subject or any other person who is attributable to their sphere of competence, or is disabled, it is possible to execute the reinstallation or reactivation of the browser add-ons.
Further information and the applicable data protection provisions of Google may be retrieved under https://www.google.com/intl/en/policies/privacy/ and under http://www.google.com/analytics/terms/us.html. Google Analytics is further explained under the following Link https://www.google.com/analytics/.
Data protection provisions about the application and use of Google+
On this website, the controller has integrated the Google+ button as a component. Google+ is a so-called social network. A social network is a social meeting place on the Internet, an online community, which usually allows users to communicate with each other and interact in a virtual space. A social network may serve as a platform for the exchange of opinions and experiences, or enable the Internet community to provide personal or business-related information. Google+ allows users of the social network to include the creation of private profiles, upload photos and network through friend requests.
The operating company of Google+ is Google Inc., 1600 Amphitheatre Pkwy, Mountain View, CA 94043-1351, UNITED STATES.
With each call-up to one of the individual pages of this website, which is operated by the controller and on which a Google+ button has been integrated, the Internet browser on the information technology system of the data subject automatically downloads a display of the corresponding Google+ button of Google through the respective Google+ button component. During the course of this technical procedure, Google is made aware of what specific sub-page of our website was visited by the data subject. More detailed information about Google+ is available under https://developers.google.com/+/.
If the data subject is logged in at the same time to Google+, Google recognizes with each call-up to our website by the data subject and for the entire duration of his or her stay on our Internet site, which specific sub-pages of our Internet page were visited by the data subject. This information is collected through the Google+ button and Google matches this with the respective Google+ account associated with the data subject.
If the data subject clicks on the Google+ button integrated on our website and thus gives a Google+ 1 recommendation, then Google assigns this information to the personal Google+ user account of the data subject and stores the personal data. Google stores the Google+ 1 recommendation of the data subject, making it publicly available in accordance with the terms and conditions accepted by the data subject in this regard. Subsequently, a Google+ 1 recommendation given by the data subject on this website together with other personal data, such as the Google+ account name used by the data subject and the stored photo, is stored and processed on other Google services, such as search-engine results of the Google search engine, the Google account of the data subject or in other places, e.g. on Internet pages, or in relation to advertisements. Google is also able to link the visit to this website with other personal data stored on Google. Google further records this personal information with the purpose of improving or optimizing the various Google services.
Through the Google+ button, Google receives information that the data subject visited our website, if the data subject at the time of the call-up to our website is logged in to Google+. This occurs regardless of whether the data subject clicks or doesn’t click on the Google+ button.
If the data subject does not wish to transmit personal data to Google, he or she may prevent such transmission by logging out of his Google+ account before calling up our website.
Further information and the data protection provisions of Google may be retrieved under https://www.google.com/intl/en/policies/privacy/. More references from Google about the Google+ 1 button may be obtained under https://developers.google.com/+/web/buttons-policy.
Data protection provisions about the application and use of Google-AdWords
On this website, the controller has integrated Google AdWords. Google AdWords is a service for Internet advertising that allows the advertiser to place ads in Google search engine results and the Google advertising network. Google AdWords allows an advertiser to pre-define specific keywords with the help of which an ad on Google’s search results only then displayed, when the user utilizes the search engine to retrieve a keyword-relevant search result. In the Google Advertising Network, the ads are distributed on relevant web pages using an automatic algorithm, taking into account the previously defined keywords.
The operating company of Google AdWords is Google Inc., 1600 Amphitheatre Pkwy, Mountain View, CA 94043-1351, UNITED STATES.
The purpose of Google AdWords is the promotion of our website by the inclusion of relevant advertising on the websites of third parties and in the search engine results of the search engine Google and an insertion of third-party advertising on our website.
If a data subject reaches our website via a Google ad, a conversion cookie is filed on the information technology system of the data subject through Google. The definition of cookies is explained above. A conversion cookie loses its validity after 30 days and is not used to identify the data subject. If the cookie has not expired, the conversion cookie is used to check whether certain sub-pages, e.g, the shopping cart from an online shop system, were called up on our website. Through the conversion cookie, both Google and the controller can understand whether a person who reached an AdWords ad on our website generated sales, that is, executed or canceled a sale of goods.
The data and information collected through the use of the conversion cookie is used by Google to create visit statistics for our website. These visit statistics are used in order to determine the total number of users who have been served through AdWords ads to ascertain the success or failure of each AdWords ad and to optimize our AdWords ads in the future. Neither our company nor other Google AdWords advertisers receive information from Google that could identify the data subject.
The conversion cookie stores personal information, e.g. the Internet pages visited by the data subject. Each time we visit our Internet pages, personal data, including the IP address of the Internet access used by the data subject, is transmitted to Google in the United States of America. These personal data are stored by Google in the United States of America. Google may pass these personal data collected through the technical procedure to third parties.
The data subject may, at any time, prevent the setting of cookies by our website, as stated above, by means of a corresponding setting of the Internet browser used and thus permanently deny the setting of cookies. Such a setting of the Internet browser used would also prevent Google from placing a conversion cookie on the information technology system of the data subject. In addition, a cookie set by Google AdWords may be deleted at any time via the Internet browser or other software programs.
The data subject has a possibility of objecting to the interest based advertisement of Google. Therefore, the data subject must access from each of the browsers in use the link www.google.de/settings/ads and set the desired settings.
Further information and the applicable data protection provisions of Google may be retrieved under https://www.google.com/intl/en/policies/privacy/.
Data protection provisions about the application and use of Instagram
On this website, the controller has integrated components of the service Instagram. Instagram is a service that may be qualified as an audiovisual platform, which allows users to share photos and videos, as well as disseminate such data in other social networks.
The operating company of the services offered by Instagram is Instagram LLC, 1 Hacker Way, Building 14 First Floor, Menlo Park, CA, UNITED STATES.
With each call-up to one of the individual pages of this Internet site, which is operated by the controller and on which an Instagram component (Insta button) was integrated, the Internet browser on the information technology system of the data subject is automatically prompted to the download of a display of the corresponding Instagram component of Instagram. During the course of this technical procedure, Instagram becomes aware of what specific sub-page of our website was visited by the data subject.
If the data subject is logged in at the same time on Instagram, Instagram detects with every call-up to our website by the data subject—and for the entire duration of their stay on our Internet site—which specific sub-page of our Internet page was visited by the data subject. This information is collected through the Instagram component and is associated with the respective Instagram account of the data subject. If the data subject clicks on one of the Instagram buttons integrated on our website, then Instagram matches this information with the personal Instagram user account of the data subject and stores the personal data.
Instagram receives information via the Instagram component that the data subject has visited our website provided that the data subject is logged in at Instagram at the time of the call to our website. This occurs regardless of whether the person clicks on the Instagram button or not. If such a transmission of information to Instagram is not desirable for the data subject, then he or she can prevent this by logging off from their Instagram account before a call-up to our website is made.
Further information and the applicable data protection provisions of Instagram may be retrieved under https://help.instagram.com/155833707900388 and https://www.instagram.com/about/legal/privacy/.
Data protection provisions about the application and use of YouTube
On this website, the controller has integrated components of YouTube. YouTube is an Internet video portal that enables video publishers to set video clips and other users free of charge, which also provides free viewing, review and commenting on them. YouTube allows you to publish all kinds of videos, so you can access both full movies and TV broadcasts, as well as music videos, trailers, and videos made by users via the Internet portal.
The operating company of YouTube is YouTube, LLC, 901 Cherry Ave., San Bruno, CA 94066, UNITED STATES. The YouTube, LLC is a subsidiary of Google Inc., 1600 Amphitheatre Pkwy, Mountain View, CA 94043-1351, UNITED STATES.
With each call-up to one of the individual pages of this Internet site, which is operated by the controller and on which a YouTube component (YouTube video) was integrated, the Internet browser on the information technology system of the data subject is automatically prompted to download a display of the corresponding YouTube component. Further information about YouTube may be obtained under https://www.youtube.com/yt/about/en/. During the course of this technical procedure, YouTube and Google gain knowledge of what specific sub-page of our website was visited by the data subject.
If the data subject is logged in on YouTube, YouTube recognizes with each call-up to a sub-page that contains a YouTube video, which specific sub-page of our Internet site was visited by the data subject. This information is collected by YouTube and Google and assigned to the respective YouTube account of the data subject.
YouTube and Google will receive information through the YouTube component that the data subject has visited our website, if the data subject at the time of the call to our website is logged in on YouTube; this occurs regardless of whether the person clicks on a YouTube video or not. If such a transmission of this information to YouTube and Google is not desirable for the data subject, the delivery may be prevented if the data subject logs off from their own YouTube account before a call-up to our website is made.
YouTube’s data protection provisions, available at https://www.google.com/intl/en/policies/privacy/, provide information about the collection, processing and use of personal data by YouTube and Google.
Parts of this Privacy Policy has been generated by the Privacy Policy Generator of the DGD – Your External DPO that was developed in cooperation with RC GmbH, which sells used computers and the German Lawyers from WBS-LAW.