This privacy policy is a legally binding agreement between you (“User”, “you” or “your”) and One World Global Trade Management Limited (“One World”, ”One World GTM”, “we”, “us” or “our”).
We greatly respect your privacy and your trust and confidence in us. We are fully committed to protecting any data that you share with us in accordance with the Data Protection Act 2018, General Data Protection Regulations and Personal Information Protection Law of the Peoples Republic of China.
This privacy policy (“Policy”) describes the types of information we may collect from you or that you may provide (“Personal Information”) on the https://owgtm.com website (“Website” or “Service”) and any of its related products and services (collectively, “Services”), and our practices for collecting, using, maintaining, protecting, and disclosing that Personal Information. It also describes the choices available to you regarding our use of your Personal Information and how you can access and update it.
If you do not agree to the processing of your personal information in the way described in this policy, please cease to access our websites or services. By continuing to access our services you are accepting the terms described within this policy.
Whilst using, accessing or consuming any of our services, we may request that you provide personal information to deliver such services and this information may be used to identify you as a specific individual, directly or indirectly (Personal Information, PI).
We commit to only requesting the minimal personal information required to deliver services including:
· Basic Personal Information – this will include your full name, your job title, your company name, your postal address, your email address and your phone number.
Sensitive personal information.
We do not intend to collect sensitive personal data unless we are legally required to do so. Examples of sensitive personal data include ethnic origin, political opinions, religion or beliefs, trade union membership, genetic or health status, sexual orientation, and criminal records. If you choose to provide sensitive personal data to us for any reason, the act of doing so constitutes your explicit consent, where such consent is necessary and valid under your local law, for us to collect and use that information in the ways described in this Privacy Notice or as described by us and accepted by you at the point where you disclosed such information. Before sensitive personal data is provided by the you, you must contact us. We will clarify to you whether the provision of the sensitive personal data is required by law or contract or is necessary for the conclusion of the contract, and whether there is an obligation to provide the sensitive personal data and the consequences of non-provision of such data. Do not provide sensitive personal data to us, unless you hereby consent to our use of that data for its legitimate business purposes and consent to the transfer and storage of such information to and from our databases.
How do we use the information we collect about you.
We may need to collect and use certain Personal Information to provide the goods and services that we provide to you. Any personal information shared with us will only be for business purposes and if permitted by law. If you do not provide the information that we request, we may not be able to provide you with the requested products or services. Any of the information we collect from you may be used for the following purposes:
· Contractual obligations
· Business support activities
· Send marketing and promotional communications.
· Send product and service updates.
· Run and operate the Website and Services
Processing your Personal Information can only be undertaken where there is a lawful basis to do so. These lawful bases are described in the Data Protection Act 2018, General Data Protection Regulations, and Personal Information Protection Law of the Peoples Republic of China and their applicability depends on how you interact with our website and/or Services. Any data processed by us will meet one of the following conditions:
· You have given your consent for one or more specific purposes;
· Provision of information is necessary for the performance of an agreement with you and/or for any pre-contractual obligations thereof;
· Processing is necessary for compliance with a legal obligation to which you are subject;
· Processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in us.
Note that under some legislations we may be allowed to process information until you object to such processing by opting out, without having to rely on consent or any other of the legal bases. In any case, we will be happy to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Information is a statutory or contractual requirement, or a requirement necessary to enter into a contract.
Your Rights
According to relevant laws, regulations and standards in the United Kingdom, as well as common practices in other countries and regions, we will ensure your following rights to your PI:
I. Access your personal information.
You have the right to access your personal Information unless laws and regulations specify otherwise. We have a duty to provide the required information upon request:
1. Your PI and types of PI held by us;
2. The source from where we obtained your PI;
3. The identity or type of any third party who has obtained your PI.
If you wish to access your data, you can do so by sending an email to hr@ugroup.co.uk
We will respond to your access request within 30-days.
II. Rectify your personal information.
When you find a mistake in your information that we are processing, you have the right to ask us to rectify it. You can submit a rectification request through the channels listed in “(I.) “Access your Personal Information”.
III. Delete your Personal Information
You can submit a request to delete your PI to us under the following circumstances:
1. If our processing of PI violates laws or regulations;
2. If we collected and used your PI without your consent;
3. If our processing of PI breaches our agreement with you;
4. If you no longer use our products or services or you have cancelled your account;
5. If we no longer provide you with products or services.
When we decide to respond to your deletion request, we will also inform the entity that acquires your PI from us and ask it to delete your PI without delay, unless otherwise specified in laws and regulations, or the entity has acquired specific authorization from you.
When you delete the information from our services, we might not immediately delete the corresponding information from our backup system but will delete it when the backup system is updated.
IV. Change the scope of your consent.
Where consent has been provided to obtain personal information, you can give or withdraw your consent at any time. To do so, please submit a rectification request through the channels listed in “(I.) Access your Personal Information”.
V. Restrict automated decision-making by information systems.
We do not use automated decision-making technologies within our company or associated companies.
VI. Respond to your above-mentioned requests.
For security, you might be required to submit written requests or prove your identity by other means. We might ask you to verify your identity before handling your request.
We will respond in 30 days. If you are not completely satisfied, you can file a complaint by sending an email to hr@ugroup.co.uk or alternately contacting the authorities’ using either method provided under the Complaints section of this policy.
We will not charge you for your reasonable requests in principle. However, a fee to reflect the cost will be imposed as appropriate on repeated requests beyond reasonable scope. As for repeated requests that are groundless and need excessive technological means (e.g., developing a new system or fundamentally changing the current practices) to fulfil, bring about risks to others’ legitimate rights and interests or are downright impractical (e.g., Involving information stored on a backup disk), we might reject.
We will not be able to respond to your request under the following circumstances:
1. Related to our compliance with the obligations under the laws and regulations;
2. Directly related to national security or defence security;
3. Directly related to public security, public health or major public interests;
4. Directly related to criminal investigations, prosecutions, trials and enforcement of court decisions, etc.;
5. We have sufficient proof that you have subjective malice or abuse of rights；
6. For the purpose of safeguarding your life, property and other important legal rights and interests or those of other individuals but it is difficult to obtain consent;
7. Responding to your request will cause serious harm to your legitimate rights and interests, or those of other individuals or organizations.
8. Involving trade secrets.
How we entrust the processing, sharing, transfer and disclosure of your personal information
Entrustment of processing
One World Global Trade Management is part of a larger group of companies owned by Uniserve Holdings. We will not share your personal information with any external vendors or companies that are not part of the Uniserve Holdings Group. If we require the assistance of any third parties, we will first obtain your explicit consent.
Sharing
We will not share your PI with any company, organization or individual other than our Company, unless with your explicit consent.
Transfer
We will not transfer your PI to any company, organization, or individual except under the following circumstances:
1. Transfer with explicit consent: after acquiring your explicit consent, we will transfer your PI to other parties within the Sample Parent Group;
2. When the transfer of PI is involved in a(n) merger, acquisition or bankruptcy, liquidation, we will require the new company or organization to which your PI is transferred to continue to be bound by this PI Protection Policy, otherwise we will require the new company or organization to seek your consent again.
Public Disclosure
We will only publicly disclose your PI under the following circumstances:
1. After we obtain your explicit consent;
2. Statutory disclosure: we might publicly disclose your PI as stipulated by laws, regulations or the mandatory requirements of government agencies however, in the particular case of China, where data is shared overseas , any such legal requests will only be complied with upon approval from the Cyberspace Administration of China. (CAC)
Privacy of children
We do not knowingly collect any Personal Information from children under the age of consent. If you are under the age of consent, please do not submit any Personal Information through the Website and Services. If you have reason to believe that a child or person under the age of consent has provided Personal Information to us through the Website and Services, please contact us to request that we delete that child’s Personal Information from our Services.
We encourage parents and legal guardians to monitor their children’s Internet usage and to help enforce this Policy by instructing their children never to provide Personal Information through the Website and Services without their permission. We also ask that all parents and legal guardians overseeing the care of children take the necessary precautions to ensure that their children are instructed to never give out Personal Information when online without their permission.
Cookies
Our Website and Services use “cookies” to help personalize your online experience. A cookie is a text file that is placed on your hard disk by a web page server. Cookies cannot be used to run programs or deliver viruses to your computer. Cookies are uniquely assigned to you and can only be read by a web server in the domain that issued the cookie to you.
We may use cookies to collect, store, and track information for security and personalization, and for statistical purposes. For further information on the cookies, we collect and their purpose, Please Click Here.
Data analytics
Our Website and Services may use third-party analytics tools that use cookies, web beacons, or other similar information-gathering technologies to collect information on how you use our website. The information gathered is used to compile statistical reports on User activity such as how often Users visit our Website and Services, what pages they visit and for how long, etc. We use the information obtained from these analytics tools to monitor the performance and improve our Website and Services. We do not use third-party analytics tools to track or to collect any personally identifiable information of our Users and we will not associate any information gathered from the statistical reports with any individual User.
Do Not Track Signals
Some browsers incorporate a Do Not Track feature that signals to websites you visit that you do not want to have your online activity tracked. Tracking is not the same as using or collecting information in connection with a website. For these purposes, tracking refers to collecting personally identifiable information from consumers who use or visit a website or online service as they move across different websites over time. How browsers communicate the Do Not Track signal is not yet uniform. As a result, the Website and Services are not yet set up to interpret or respond to Do Not Track signals communicated by your browser. Even so, as described in more detail throughout this Policy, we limit our use and collection of your Personal Information. For a description of Do Not Track protocols for browsers and mobile devices or to learn more about the choices available to you, visit internetcookies.com
Email marketing
We offer electronic newsletters to which you may voluntarily subscribe at any time. We are committed to keeping your e-mail address confidential and will not disclose your email address to any third parties except as allowed in the information use and processing section or for the purposes of utilizing a third-party provider to send such emails. We will maintain the information sent via e-mail in accordance with applicable laws and regulations.
In compliance with the Privacy and Electronic Communications Regulations (PECR), all e-mails sent from us will clearly state who the e-mail is from and provide clear information on how to contact the sender. You may choose to stop receiving our newsletter or marketing emails by following the unsubscribe instructions included in these emails or by contacting us.
Links to other resources
The Website and Services contain links to other resources that are not owned or controlled by us. Please be aware that we are not responsible for the privacy practices of such other resources or third parties. We encourage you to be aware when you leave the Website and Services and to read the privacy statements of each and every resource that may collect Personal Information.
Information security
We secure information that you provide on computer servers in a controlled, secure environment, protected from unauthorized access, use, or disclosure. We maintain reasonable administrative, technical, and physical safeguards in an effort to protect against unauthorized access, use, modification, and disclosure of Personal Information in our control and custody. However, no data transmission over the Internet or wireless network can be guaranteed.
Therefore, while we strive to protect your Personal Information, you acknowledge that:
· There are security and privacy limitations of the Internet which are beyond our control;
· The security, integrity, and privacy of any and all information and data exchanged between you and the Website and Services cannot be guaranteed;
· Any such information and data may be viewed or tampered with in transit by a third party, despite best efforts.
Data breach
In the event we become aware that the security of the Website and Services has been compromised or Users’ Personal Information has been disclosed to unrelated third parties as a result of external activity, including, but not limited to, security attacks or fraud, we reserve the right to take reasonably appropriate measures, including, but not limited to, investigation and reporting, as well as notification to and cooperation with law enforcement authorities. In the event of a data breach, we will make the necessary reporting to the authorities in both the United Kingdom and China and make reasonable efforts to notify affected individuals if we believe that there is a reasonable risk of
harm to the User as a result of the breach or if notice is otherwise required by law. When we do, we will send you an email.
Changes and amendments
We reserve the right to modify this Policy or its terms related to the Website and Services at any time at our discretion. When we do, we will revise the updated date at the bottom of this page. We may also provide notice to you in other ways at our discretion, such as through the contact information you have provided.
An updated version of this Policy will be effective immediately upon the posting of the revised Policy unless otherwise specified. Your continued use of the Website and Services after the effective date of the revised Policy (or such other act specified at that time) will constitute your consent to those changes. However, we will not, without your consent, use your Personal Information in a manner materially different than what was stated at the time your Personal Information was collected.
Acceptance of this policy
You acknowledge that you have read this Policy and agree to all its terms and conditions. By accessing and using the Website and Services and submitting your information you agree to be bound by this Policy. If you do not agree to abide by the terms of this Policy, you are not authorized to access or use the Website and Services.
Contacting us
If you have any questions, concerns, or complaints regarding this Policy, the information we hold about you, or if you wish to exercise your rights, we encourage you to contact us using the details below:
One World GTM
6 Chapel Place
London
EC2A 3DQ
0202 3848 8751
We will attempt to resolve complaints and disputes and make every reasonable effort to honour your wish to exercise your rights as quickly as possible and, in any event, within the timescales provided by applicable data protection laws.
Complaints
If you are not entirely satisfied with our reply, especially if our processing of PI hurts your legal rights and interests, you can seek solutions through the following external channels:
One World GTM
6 Chapel Place
London
EC2A 3DQ
0202 3848 8751
This document was last updated on November 14, 2023