1. Status and scope
This policy takes effect when the approved V4.0 website is publicly launched and applies to personal data handled through the Dechoele website, RFQ and BOM enquiries, related business communications and transaction administration.
It is intended for business-to-business interactions. The collection-specific notice presented at the RFQ form forms part of this policy and is provided on or before personal data is collected.
Dechoele handles personal data in accordance with the Personal Data (Privacy) Ordinance (Cap. 486) and its Data Protection Principles. Website operation, staff access, service-provider arrangements and deletion procedures must remain consistent with this policy.
2. Data user and contact details
The data user is HONG KONG DECHOELE TECHNOLOGY CO., LIMITED, incorporated on 2024-04-29. “Dechoele” is the public-facing brand used on the website.
Public contact details:
- Email: [email protected]
- Telephone: +852 69534531
- WhatsApp: +852 69534531
- Contact address: Room D3, 11/F, Luk Hop Industrial Building, 8 Luk Hop Street, San Po Kong, Kowloon, Hong Kong
Requests concerning access to or correction of personal data should be addressed to the Privacy Contact at the email or postal address above.
3. Personal data we collect
Business enquiries and website use may involve:
- contact details and business information supplied by an enquirer, such as a name, company, business email, telephone number and destination country or region;
- component requirements, including part numbers, manufacturers, package information, quantities, target prices, currencies and notes supplied by the enquirer;
- BOM content and attachments that an enquirer chooses to provide through an approved channel;
- the content and history of enquiries, quotations and related business communications;
- minimal technical or security logs that may be produced by the website, hosting environment or protective services.
The RFQ/BOM workflow also records a submission reference, the applicable policy and acknowledgement versions, the acknowledgement time and limited security metadata. Accepted BOM files are safety-checked and stored in private application storage rather than a public web directory.
4. Purposes of use
Information supplied through an approved channel is used to:
- receive, assess and respond to a business enquiry;
- prepare, discuss and administer quotations and written orders;
- communicate about requested components, documentation, delivery requirements or quality questions;
- maintain proportionate business, accounting, dispute and legal records;
- protect the website, communications and business systems from misuse or security incidents.
Personal data is not used for an unrelated new purpose without the data subject's prescribed consent or another basis permitted by applicable law.
5. Choice and consequences
Providing information for an initial enquiry is generally voluntary. However, without sufficient contact information and component requirements, the company may be unable to assess or respond to the enquiry. Information required for an accepted order may also be governed by the applicable written quotation, order documents and legal obligations.
The RFQ form identifies required and optional fields and presents the collection notice below before submission.
6. RFQ Collection Notice
Submitting an RFQ or BOM enquiry is voluntary. If an enquirer chooses to submit, fields marked required must be provided so that Dechoele can identify the request, review the component requirements and respond. The enquiry cannot be processed if required information is not provided; optional fields may be left blank.
The submitted contact details, sourcing requirements, message and any BOM file are used to receive and assess the enquiry, communicate about sourcing or a quotation, protect the service from misuse, and keep proportionate business and audit records.
The information may be accessed by authorised personnel of HONG KONG DECHOELE TECHNOLOGY CO., LIMITED and, where necessary for those purposes, by hosting, security and email providers, relevant suppliers or logistics providers, and professional advisers. An RFQ submission is not used for direct marketing without a separate choice.
RFQ records and BOM files are retained on an ongoing basis without an automatic expiry date, subject to periodic review and deletion or anonymisation when they are no longer necessary for the stated purposes or applicable legal requirements.
A person may request access to or correction of personal data by contacting the Privacy Contact at [email protected] or Room D3, 11/F, Luk Hop Industrial Building, 8 Luk Hop Street, San Po Kong, Kowloon, Hong Kong.
7. Recipients and service providers
Access is limited to people and organisations that need the information for a stated purpose. Relevant classes include authorised company personnel; hosting, security, enterprise email and IT service providers; suppliers and logistics providers involved in an enquiry or order; banks, insurers, auditors, lawyers and other professional advisers; and public authorities where disclosure is required or permitted by law.
Company email uses an Alibaba enterprise email service. WhatsApp is an optional third-party contact route: selecting its link leaves the Dechoele website, and information sent through WhatsApp is processed through that provider's service. Service providers are required, through contractual or other practicable controls, to use personal data only for authorised purposes and to protect it appropriately.
8. Cross-border handling
Dechoele serves global business enquiries, so personal data may be accessed, processed or stored outside Hong Kong by relevant service providers, suppliers, logistics providers or advisers for the purposes stated in this policy.
Dechoele uses contractual or other practicable controls appropriate to the circumstances to restrict use, onward transfer, retention and disclosure and to require suitable security for personal data handled outside Hong Kong.
9. Retention and deletion
RFQ enquiry records and uploaded BOM files are retained on an ongoing basis without an automatic expiry date so that Dechoele can maintain sourcing history, respond to follow-up enquiries, administer transactions and preserve necessary business, audit, compliance and dispute records.
Retention is reviewed periodically. Personal data and files are deleted or anonymised when they are no longer necessary for those purposes, subject to applicable legal, accounting, contractual, security and legal-claim requirements. Backup copies are removed or rendered inaccessible through the applicable backup cycle.
10. Security
Dechoele uses practicable technical and organisational safeguards appropriate to the nature of the data and limits access to people with a business need. Measures include controlled access, private attachment storage, upload validation and malware scanning, security logging, backups and incident handling.
No internet or email system can be guaranteed completely secure. Security controls and access rights are reviewed and adjusted in light of operational and technical risks.
12. Direct marketing
An RFQ or BOM submission is not consent to direct marketing. If Dechoele proposes to use personal data for direct marketing, it will first provide the information required by Part 6A of the Personal Data (Privacy) Ordinance, obtain the required consent or indication of no objection through a separate choice, and provide a free method to opt out. Dechoele will stop the relevant direct-marketing use after receiving a valid opt-out request.
13. Access and correction
A data subject may request access to and correction of personal data in accordance with the Personal Data (Privacy) Ordinance. A data access request should be made in writing in Chinese or English, preferably using the form specified by the Privacy Commissioner for Personal Data, and sent to the Privacy Contact at the email or postal address in section 2.
Dechoele may request reasonable identity verification and may charge a fee permitted by law for a data access request. It will respond within the period required by the Ordinance, subject to any lawful ground for refusal. A request for deletion or anonymisation will be considered under the retention purposes and applicable legal obligations described above.
14. Children
The website is intended for business-to-business component enquiries and is not directed to children. A person who believes a child has submitted personal data without appropriate authority should contact the Privacy Contact so the circumstances can be reviewed and appropriate action taken.
15. Contact and policy changes
Questions about this policy may be sent to [email protected], by telephone at +852 69534531, or to the contact address above.
This policy becomes effective when the approved V4.0 website is publicly launched. The calendar date of activation must be recorded on this page and in the launch record.