Privacy Policy

Effective on: 1 November 2021

Peak Pacific Limited (“Peak Pacific”, “we”, “us”, “our”) takes the protection of personally identifiable information (“Personal Data”) very seriously. This Privacy Policy (this “Policy”) addresses users (“Data Subjects”) whose Personal Data we process in our web applications, the publicly accessible components of our website peakpacificgroup.com (the “Website”), or when we are contacted on the Website or by email. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.

1.1 INFORMATION WE MAY COLLECT FROM YOU

We may collect and process the following data about you:

• Information that you provide. This may be by filling in forms on our site, providing us with your business card or contact details, providing us with your information in registering to use our client wiki pages, and/or or by corresponding with us by phone, email or otherwise. This includes information provided at the time of registering to use our site, subscribing to our services, posting material, or requesting further information and/or services. We may also ask you for information if you report a problem with our site. The information that you provide to us may include name, email address, company and position, address, and telephone number as well as the details contained in your query;
• Browsing and Cookies. No personal information – such as your name, address, contact phone numbers or email address – will be collected if you are only browsing our site, but we use cookies on our site as specified below.

For additional details of transactions carried out through our site or other types of information collected you may contact us at marcom@peakpacificgroup.com.

1.2 COOKIES

Our site uses cookies to distinguish you from other visitors to provide you with a better experience and to help us improve our site. By continuing to browse the site, you are agreeing to our use of cookies.

A cookie is a small data file placed on the hard drive of your computer when you visit a website. A “session cookie” expires when you end your session (i.e. close your browser). A “persistent cookie” stores information on your hard drive so when you end your session and return to the same website at a later date, the cookie information is still available. A “web beacon” is a small string of code that represents a clear graphic image, a redirect URL or JavaScript and is used in conjunction with a cookie.

Our site may use session and persistent cookies. The cookies placed by the Peak Pacific server are readable only by Peak Pacific, and cookies cannot access, read, or modify any other data on your computer. We may use web beacons alone or in conjunction with cookies to compile information about your usage of our site and interaction with emails from Peak Pacific. For example, we may place web beacons in marketing emails that notify us when you click on a link in the email that directs you to our site, in order to improve our site and email communications.

Our site may contain links to other websites including share and/or “like” buttons. These other websites, services and applications may set their own cookies on users’ computers, collect data or solicit personal information. You should refer to their privacy policies to understand how your information may be collected and/or used.

Here is which cookies Peak Pacific uses on its site:
1.2.1 Preference Cookies

Peak Pacific uses preference cookies to collect information about your choices and preferences, and to allow us to remember language or other local settings and customize our site accordingly. Specific preference cookies used by us are the following:

1.2.2 Analytical Cookies

Peak Pacific uses analytics cookies to collect information about your use of our site, and to enable us to improve the way it works. For example, analytics cookies show us which are the most frequently visited pages on our site, help us record any difficulties you have with our site, and show us whether our advertising is effective or not. This allows us to see the overall patterns of usage on our site, rather than the usage of a single person.

We use the information to analyse the site traffic, but we do not examine this information for individually identifying information. Specific analytical cookies used by us are the following:

COOKIE NAME	COOKIE TYPE	COMPANY	EXPIRATION FROM WHEN IT IS FIRST PLACED	DESCRIPTION
_utma	Persistent	Google Analytics	24 months	Keeps track of the number of times a visitor has been to the site pertaining to the cookie, when their first visit was, and when their last visit occurred.
_utmb	Session	Google Analytics	30 months	Takes a timestamp of the exact moment in time when a visitor enters a site.
_utmc	Session	Google Analytics	Immediately after browser closes	Takes a timestamp of the exact moment in time when a visitor leaves a site.
_utmv	Persistent	Google Analytics	24 months	Used to store visitor-level custom variable data. The cookie is updated every time data is sent to Google Analytics.
_utmt	Persistent	Google Analytics	after 10 minutes	This cookie is set by Google Analytics. According to their documentation it is used to throttle the request rate for the service – limiting the collection of data on high traffic sites.
_utmz	Persistent	Google Analytics	6 months	Keeps track of where you came from, what search engine you used, what link you clicked on, what keyword you used, and where they were in the world when you accessed a website. It expires in 6 months.

1.2.3 Marketing Cookies

Third party vendors, including LinkedIn, may show our ads on sites across the internet.

We, and third party vendors, including LinkedIn, use first-party cookies (such as the Google Analytics cookie) and third-party cookies (such as the DoubleClick cookie) together to inform, optimize, and serve ads based on someone’s past visits to our website.

1.2.4 Controlling Cookies

Most web browsers have a “help” menu where you can review how to prevent your browser from accepting new cookies, how to have your browser alert you when you receive a new cookie or how to fully disable cookies on your browser. You can learn more about cookies at sites like www.aboutcookies.org. If you use your browser settings to block all cookies, you may not be able to access all or parts of our site.

1.2.5 reCAPTCHA

Peak Pacific uses reCAPTCHA, a free service from Google LLC (located at 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA, hereafter also referred to as “Google”) that helps protect our website input forms from spam and abuse by keeping automated software out of our website.

With this service, we can differentiate between information that has been entered into a form by a human and information that has been entered by an automated machine. The service includes the sending of the IP address and possibly other data required by Google for the reCAPTCHA service to Google. To the best of our knowledge, the referrer URL, the IP address, the behaviour of website visitors, information about the operating system, browser and length of the visit, cookies, display instructions and scripts, the inputting behaviour of the user as well as the mouse movements in the reCAPTCHA checkbox area are transmitted to Google. The IP address transferred by reCAPTCHA is not commingled with other data by Google unless you are logged-in to your Google account at the time when you are using the reCAPTCHA plug-in.

If you want to prevent this transfer and storage of data by Google about you and your behaviour on our website, you must log out of Google before you visit our website and/or use the reCAPTCHA plug-in. The information obtained via the reCAPTCHA service is used in accordance with Google’s

Terms https://policies.google.com/terms and

Privacy Policy https://policies.google.com/privacy

1.3 WHERE WE STORE YOUR PERSONAL DATA AND HOW LONG FOR

Our site is hosted on servers located in Germany and support being provided by our Peak Pacific teams, however the personal information that we collect from you is input into our Zoho CRM database, which is hosted at Zoho’s ISO/IEC 27001 certified data center facilities.

For users based in the European Economic Area (EEA), this means that the data that we collect from you via our site will be transferred to and stored outside the EEA. It may also be processed by staff operating outside the EEA who work for us.

Unfortunately, the transmission of information via the internet is almost never completely secure. Although we will do our best to protect your personal data, we cannot guarantee the complete security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorized access.

We will keep a copy of your personal data for as long as you remain registered with our site/the applicable service or the contact person at any organisation we are dealing with and thereafter for such period as may be required for legal, audit and compliance purposes.

This does not affect your right to opt out from receiving marketing communications, as outlined in the section “Your rights” below. If at any time after you are no longer registered with our site/the applicable service or are no longer the contact person at the applicable organisation that we are dealing with, you may request that your details are deleted from our CRM system, however you should be aware that if your details are deleted, this will mean we will have no record of any opting out that you may have requested and that you therefore may receive unsolicited communications in the future.

1.4 USES MADE OF THE INFORMATION

We use information held about you in the following ways:

• To provide you with information via post, email, or telephone, about our products or services that you request from us or which we feel may interest you, where you have consented to be contacted for such purposes;
• To carry out our obligations arising from any contracts entered into between you and us or to enable us to deal with any query you have raised;
• To allow you to participate in interactive features of our service, when you choose to do so;
• To notify you about changes to our service;
• To administer our site and for internal operations, including trouble shooting, data analysis, testing, research, statistical and survey purposes and as part of our efforts to keep our site safe and secure.

This will include your details being included in our Zoho CRM database.

1.5 DISCLOSURE OF YOUR INFORMATION

We may disclose your personal information to any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, provided however that we shall remain responsible for the treatment of such group members of your personal data in accordance with this policy. As stated above, Peak Pacific has entered into EU Model Clauses with its group entities to ensure any such disclosure is on a legal basis.

Our general policy is not to disclose any personal data to a third party except with your prior consent. However, we may disclose your personal information to third parties:

• If we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets;
• If Peak Pacific or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets;
• If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our terms of business and other agreements; or to protect the rights, property, or safety of Peak Pacific, our customers, or others. This may include exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

1.6 LEGAL BASIS OF OUR PROCESSING OF YOUR PERSONAL DATA

We process your personal data on the basis of your consent (in relation to sending you marketing information following your submitted request through our site) and (alternatively or additionally) for our legitimate interests of promoting, growing and developing our business and, where you are a customer, in order to perform our obligations under the contract between us.

1.7 YOUR RIGHTS

You have the right to ask us not to process your personal data for marketing purposes.

You may also choose not to receive publications or certain other communications from Peak Pacific by explicitly indicating so in the appropriate section of the Registration Form or by opting-out by phone, email or via direct marketing emails sent to you.

We will inform you (before collecting your data) if we intend to use your data for marketing purposes or if we intend to or may disclose your information to any third party for such purposes. You can exercise your right to prevent such processing by (un)checking certain boxes on the forms we use to collect your data. You can also exercise the right at any time by contacting us at marcom@peakpacificgroup.com or by unsubscribing per the method outlined in any emails sent or during any phone calls with you.

Our site may, from time to time, contain links to and from the websites of our partner networks, clients, and/or affiliates. If you follow a link to any of these websites, please note that these websites are subject their own privacy policies and that we do not accept any responsibility or liability for these sites and policies. Please check these policies before you submit any personal data to these websites.

You also have the right to ask Peak Pacific to amend inaccurate personal data or to delete it. However, you should be aware that if you request your details to be deleted, this will mean we will have no record of any opting out that you may have requested and that you therefore may receive unsolicited communications in the future. If you send us any personal information in digital format, such as photographs, you are entitled to ask for a copy of this to be sent to you.

Where you are based in the EU you have the right to contact your local data protection authority and you can request details of how to do this by contacting us at:
marcom@peakpacificgroup.com

Any queries concerning your rights or the exercising of them and any complaints concerning the processing of your personal data should be sent to marcom@peakpacificgroup.com.

1.8 ACCESS TO INFORMATION

We are subject to the Personal Data (Privacy) Ordinance of the Hong Kong Special Administrative Region and, for our processing activities in Europe, the General Data Protection Regulation (EU) 2016/679 (GDPR). The Ordinance and GDPR give you the right to verify whether we hold your personal data and (have) access your personal data. You have the right rectify any inaccurate or incomplete personal data held about you. You also have the right the withdraw consent to receiving email communications from us at any time, as well as the right to erasure.

1.9 CHANGES TO OUR PRIVACY POLICY

This policy may be updated by us from time to time, so please check this policy periodically to ensure you are aware of our latest policies.

1.10 CONTACT

Questions, comments, and requests regarding this privacy policy are welcomed and should be addressed to marcom@peakpacificgroup.com. Complaints should be sent to the same address.

Our corporate details are:
Peak Pacific Limited
Level 15, Lee Garden Two
28 Yun Ping Road, Causeway Bay
Hong Kong
Tel. +852 3959 0721

Please allow up to four weeks for us to reply.