Privacy Policy

SgT Limited is an independent service provider dedicated to building risk management solutions involving testing, inspection, and certification services listed on the website (https://www.sgtgroup.net) and all other related sites, applications and tools where this Privacy Policy appears or is linked to (collectively, the “Site”).

1. WHAT INFORMATION DO WE GATHER ABOUT YOU?

The information gathered when you interact with the Site falls into two categories:

1. Personal information, which includes personal information you supply when you subscribe, complete a survey, provide comments, enter a contest or provide other information including your email address.
2. Non-personal information collected through technology, which includes tracking information collected by us as well as third parties.

1) Voluntary Submission

SgT Limited does not collect personally identifying information about any individual Site user except when knowingly provided by such individual. For example, we may ask you for information, such as your name and contact information such as your e-mail address when you register to become a member of the Site or when you apply for a job offer. You always have the option not to provide the information we request. If you choose not to provide the information we request, you can still visit most of the Site, but you may be unable to access certain options and services. When you register or become a member of the Site or provide information to SgT Limited in any other manner, you agree to provide only true, accurate, current and complete information.

The processing is implemented for the following purposes:

• the management and follow-up of exclusive content supply ;
• the management and follow-up of technical assistance request ;
• the management of job application ;
• registration to the newsletter and prospecting, e.g. commercial;
• the management and follow-up of requests for information and comments made by users ;
• the reporting of site access ;
• the measure of quality, satisfaction and attendance ;
• determining whether marketing campaigns are effective ;
• enhancing data security.

2) Non-Personal Information Collected Using Technology

We may collect non-personal information about the computer, mobile device or other device you use to access the Site, such as IP address, geolocation information, unique device identifiers, browser type, browser language and other transactional information.

We use “cookies,” Web beacons, HTML5 local storage and other similar technologies. These technologies allow us to manage access to and use of the Site, recognize you and provide personalization, and help us understand how people use the Site.
The main deposited cookies are detailed in the table below:

As is true of most web sites, we gather certain information automatically and store it in log files. This information may include Internet protocol (IP) addresses (the region or general location where your computer or device is accessing the Internet), browser type, operating system and other usage information about the use of the Site, including a history of the pages you view.

We have hired third parties to provide us information, reports and analysis about the usage, browsing patterns of our users. They may independently record the type of device and operating system you are using, general location information, as well as events that occur within our apps, such as how often you use our apps.

Some of our mobile applications can deliver content based on your current location if you choose to enable that feature of the app. If you enable the location-based feature, your current location will be stored locally on your device, which will then be used by the app. If you elect to have a location-based search saved to your history, we will store that information on our servers. If you do not enable the location-based service, or if an app does not have that feature, the app will not transmit to us, and we will not collect or store, location information.

The ads in our apps are not targeted to you based on your current GPS location, but they may be targeted to you based on your ZIP code or device’s IP address.
We may receive information about you from third parties. For example, if you access our websites or service through a third-party connection or log-in, for example, through Facebook Connect, by “following,” “liking,” linking your account to the Site service, etc., that third party may pass certain information about your use of its service to the Site. This information could include, but is not limited to, the user ID associated with your account (for example, your Facebook UID), an access token necessary to access that service, any information that you have permitted the third party to share with us, and any information you have made public in connection with that service, including your public profile picture, news feed, posts on your wall (including your friends’ posts on your wall), friends list, etc. You should always review, and if necessary, adjust your privacy settings on third-party websites and services before linking or connecting them to the Site service. You may also unlink your third party account from the Site by adjusting your settings on the third party service. If you unlink your third party account, we will remove the information collected about you in connection with that service.

2. WHAT DO WE DO WITH THE INFORMATION WE GATHER ABOUT YOU?

Data processing is implemented only if at least one of the following conditions is met:

• Your consent to the processing operations has been collected;
• The existence of our legitimate interest, or that of a third party, which justifies to implement the said processing of personal data;
• The performance of a contract that binds us to you requires to implement the processing of personal data;

we are under legal and regulatory obligations to implement the said processing of personal data.

If you have given consent to the processing of your data you can freely withdraw such consent at any time by emailing SgT Limited to privacy@sgtgroup.net

If you do withdraw your consent, and if SgT Limited does not have another legal basis for the processing of your data, then SgT Limited will stop the processing of your personal data.

If SgT Limited has another legal basis for the processing of your data, then SgT Limited may continue to do so subject to your legal interests and rights.

1) Provide the information You Request

We use the information we gather about you to enable your use of the Site and fulfill your requests for certain information, such as sending out electronic newsletters and enabling you to participate polls, contests and message boards.

2) Statistical Analysis

We perform statistical, demographic and marketing analyses of users of the Site, and their subscribing and purchasing patterns, for product development purposes and to generally inform advertisers about the nature of our subscriber base. We use this information for analysis purposes, including analysis to improve customer relationships.

3) Customizing Your Experience and Relevant Advertising

We use the information that we collect to allow advertising to be targeted to the users for whom such advertising is most pertinent. We also use this information to customize certain features of the Site to provide you with an enhanced experienced based on the type of device you are using to access the Site, and in certain cases, provide you with requested services. We will not use your personal information to send you any marketing materials unless we have received your express consent.

We may use demographic and preference information to allow advertising on the Site to be targeted to the users for whom they are most pertinent. This means users see advertising that is most likely to interest them, and advertisers send their messages to people who are most likely to be receptive, improving both the viewer’s experience and the effectiveness of the ads. 

SgT Limited can also provide users’ personal information to companies that provide services to help SgT Limited in its activities.

These companies are only authorized to use such personal information to provide us with the services we provide you. SgT Limited does not sell personal information to third parties.

Some personal data may be addressed to third parties or legally empowered authorities in order to fulfill our legal, regulatory or conventional obligations.

3. SHARING OF YOUR INFORMATION

Personal data held by SgT Limited relating to an individual will be kept confidential but may be provided to the following parties:

1. any actual or proposed assignee, transferee, participant or sub-participant of our rights or business; and
2. any government department or other appropriate governmental or regulatory authority for the purposes of meeting legal and regulatory requirements.
3. any agent, contractor or third party who provides administrative, technology or other services (including direct marketing services) to SgT Limited and/or our affiliates and who has a duty of confidentiality to the same;

The main third parties to which SgT Limited provide your data in its activities are listed hereafter:

1. HubSpot
   1. The Company uses HubSpot to provide services available on the Website. The Website is hosted by the HubSpot. The Company uses customer relationship management (CRM) via HubSpot. HubSpot helps track your use, and issues reports on your activity.
   2. Privacy Policy https://legal.hubspot.com/privacy-policy
   3. HubSpot Data Processing Agreement: https://legal.hubspot.com/dpa

2. Facebook
   1. Facebook Pixel is a web service to measure actions and build audiences. The Company uses it to track your use of the Website, and issue reports on your activity.
   2. Privacy Policy https://www.facebook.com/privacy/explanation#)

3. Google Analytics
   1. Google Analytics is a web analytics service. The Company uses it to track your use of the Website, and issue reports on your activity.
   2. see their privacy policy https://www.google.com/policies/privacy/)

4. Google AdWords
   1. Google AdWords is an online advertising service. The Company uses it to provide relevant advertisement.
   2. see their privacy policy https://www.google.com/policies/privacy/)

4. PRIVACY OF CHILDREN

Kids under 13: Do not send any information about yourself to us–including information such as your name, address, or e-mail address. We do not knowingly collect personally identifiable information from children under 13. In the event that we learn we have collected any personal information from a child under the age of 13 we will delete that information from our database as quickly as possible.

5. RETENTION OF YOUR PERSONAL INFORMATION

We will not keep personal information longer than is legally permitted. We will purge unnecessary personal information from our system in accordance with our internal procedures.

6. SECURITY

Protection of your personal information is our priority. We will ensure that your personal information will be protected against unauthorized access. Your personal information may be accessed or transferred to third parties listed in paragraph 3. Although we will do our best to protect and secure your personal information, we cannot guarantee the security of your personal information transmitted over the Internet or any telecommunications networks.

7. YOUR RIGHTS

You have rights to request access to or correction of personal data about you that is held by us. 
Please note that we also grant you a right of portability, interrogation regarding the data that concerns you, to lodge a complaint with a supervisory authority, a right to be “forgotten” and to oppose commercial prospecting, as well as the right to dispose of your data after death by writing to the company. You can object to the company using your personal data for profiling you or making automated decisions about you.

To exercise your rights, please contact our Privacy Officer at privacy@sgtgroup.net (or by writing to the following address: SgT Group, Rooms 804-5, 8/F, Sing Shun Centre, 495 Castle Peak Road, Lai Chi Kok, Kowloon, Hong Kong), by accompanying your request with a copy of a signed identity document.

8. JURISDICTION AND CROSS-BORDER TRANSFER

Your Personal Information can be stored and processed in any country where we have facilities or in which we engage service providers, and by using the Services you understand that your information will be transferred to countries outside of your country of residence, which may have data protection rules that are different from those of your country. In certain circumstances, courts, law enforcement agencies, regulatory agencies or security authorities in those other countries may be entitled to access your Personal Information.

If you are located in the European Economic Area (comprised of the EU Member States, Iceland, Liechtenstein, and Norway, together “EEA”): Some of the non-EEA countries are recognized by the European Commission as providing an adequate level of data protection according to EEA standards (the full list of these countries is available at: http://ec.europa.eu/justice/data-protection/international-transfers/adequacy/index_en.htm). For transfers from the EEA to countries not considered adequate by the European Commission, we have put in place adequate measures, such as standard contractual clauses adopted by the European Commission to protect your Personal Information.

9. HOW TO CONTACT US

If you have any questions about this Privacy Policy please contact us at privacy@sgtgroup.net.

10. HOW WILL I KNOW IF THE PRIVACY POLICY IS CHANGED?

If we make any material changes we will notify you by email (sent to the e-mail address specified in your account) or by means of a notice on this website prior to the change becoming effective. We encourage you to periodically review this page for the latest information on our privacy practices.