Privacy Policy

CIMC Enric Holdings Limited
established for protection of personal data from EEA

CIMC Enric Holdings Limited (“we” or “us”) is committed to protecting and respecting the privacy of our potential, current and past customers, suppliers, business partners and investors in the European Economic Area (“EEA”) and/or their employees whose personal information is being processed by us (“you”). This privacy policy (the “Privacy Policy”) sets out our policy on when and how we use your personal information, meaning any information that can directly or indirectly identify you (“Personal Data”), that you or others provide to us, including through our websites (the “Website”) or in a particular business context, for example sales, after-sales support, marketing, business Complete enough.
development and investor relations (the “Businesses”).

Your privacy is of the utmost importance to us. We want to make sure you fully understand the terms and conditions surrounding the capture and use of your Personal Data. This Privacy Policy describes what Personal Data we collect about you, how we use it, and the rights you have in relation to that collection and usage. Please read this Privacy Policy carefully to understand what we do.

Who we are:

We are a company, headquartered in the People’s Republic of China (“China”), listed on the Hong Kong Stock Exchange, mainly active in the energy, chemical and liquid food equipment industry segment. You may contact us through the contact details mentioned below. 

For the purposes of the General Data Protection Regulation and any other applicable data protection and privacy laws and regulations (“Data Protection Legislation”), we will be the data controller for your Personal Data of which we determine the purpose and means of processing.

Personal Data we may collect:

The types of Personal Data we collect depend on the particular context of the Businesses and the purposes for which Personal Data is collected. It may include:

• Business contact information, for example your name, business e-mail address, work address and telephone number;
Resumes or cvs of you for investing projects;
We collect the Personal Data to enable us, for example, to provide you with our products and/or services, or to inform you from time to time on services, events or new offerings that may be of interest to you. We may also receive details about you from third parties who have provided us with your Personal Data under appropriate legal grounds for sharing. We will always inform you of how we received your Personal Data when we contact you.

We also collect Personal Data from you when you voluntarily choose to provide us with such information, most importantly when you communicate with us via email, provide us with your contact details or by any other means.

We make efforts to avoid processing special categories of Personal Data, namely information which may relate to racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, or health or sex life. However, when a compelling business reason exists, we may process such Personal Data in accordance with the applicable Data Protection Legislation and any related designated safeguards.

Where we need to collect Personal Data by law, or under the terms of an agreement we have with you and you fail to provide that Personal Data when requested, we may not be able to perform the contract we have or are trying to enter into with you. In this case, we may have to cancel the contract you have with us but we will notify you if this is the case at the time.

How we use your Personal Data:

We will use your Personal Data in relation to the services including:
To perform sale contracts or conduct other commercial activities like investing/finical  projects ;
• To perform our obligations under anti-money laundering and other laws;
• To give you information that you request from us and to improve our services;
• Any relevant testing or statistical analysis as appropriate.

If you contact us, we keep a record of your communication to help solve any issues you might be facing or questions that you may have. We do not sell, rent, share or otherwise disclose Personal Data unless as mentioned in this Privacy Policy.

Incidentally, we may process your Personal Data where it is needed in relation to legal claims or where it is needed to protect your interests (or someone else's interests) and you are not capable of giving your consent.

Lawful basis for processing:

If you reside within the EEA, our processing of your Personal Data will be legitimized as follows:

1. Whenever we require your consent for the processing of your Personal Data such processing will be justified pursuant to Article 6(1) lit. (a) of the GDPR. This article in the GDPR describes when processing can be done lawfully;
2. If the processing of your Personal Data is necessary for the performance of a contract between you/your company and us or for taking any pre-contractual steps upon your request, such processing will be based on GDPR Article 6(1) lit. (b). If this Personal Data is not processed, we will not be able to execute the contract with you/your company, for example your employer purchase our products;
3. Where the processing is necessary for us to comply with a legal obligation, we will process your Personal Data on basis of GDPR Article 6(1) lit. (c); and/or
4. And where the processing is necessary for the purposes of our legitimate interests, such processing will be made in accordance with GDPR Article 6(1) lit. (f), for example to detect fraud or share information that we think may be of interest to you.

Data retention:

We will only retain your Personal Data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, accounting, or reporting requirements. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the Personal Data, the potential risk of harm from unauthorized use or disclosure of your Personal Data, the purposes for which we process your Personal Data and whether we can achieve those purposes through other means, and the applicable legal requirements.

How we protect your Personal Data:

To protect your Personal Data from misuse, unauthorized access or disclosure, loss, alteration, or destruction, we use appropriate technical, administrative, physical and procedural security measures that are consistent with local and international information practices. These measures include:

• Physical safeguards, such as locked doors and file cabinets, controlled access to our facilities;
• Technological safeguards, such as use of anti-virus and endpoint protection software, encryption, and monitoring of our systems and data centers to ensure compliance with our security policies; and
• Organizational safeguards, through training and awareness programs on security and privacy, to ensure employees understand the importance and means by which they must protect personal data, as well as through privacy policies and policy standards that govern how we treat personal data.However, you should be aware that providing Personal Data over the internet or otherwise can never be guaranteed as being completely safe.

Personal Data we disclose:

As a general matter, we do not disclose or sell your Personal Data to any third parties, except for disclosing your Personal Data to trusted third parties so designated by us, who assist us in operating the Website, conducting the Businesses, or servicing you (“Trusted Third Parties”). We may transmit your Personal Data to such Trusted Third Parties. We will only transmit your Personal Data to Trusted Third Parties following their agreement and ongoing commitment to keep all Personal Data confidential. This Personal Data is given to Trusted Third Parties based on our instructions and in compliance with our Privacy Policy and any other confidentiality and security measures.

We may also release your Personal Data when we believe such release is necessary to comply with applicable laws, enforce our policies, or protect our legal rights, property, or safety, or those of third parties.

Transfer of Personal Data outside the EEA:

Your Personal Data may be transferred to us and processed in China under our control. We may further share your Personal Data with our parent companies, subsidiaries, affiliates or service providers. Your Personal Data may, therefore, be transferred to and/or made accessible from countries out of the EEA.

The laws of China according to the EU authorities do not (yet) offer the same amount of data protection as the EU. In most cases, such transfers will be necessary for the performance of your/your employer’s contract or a contract concluded in your interest. Where otherwise applicable, we may also rely on binding corporate rules where our partners or service providers have adopted such internal policies approved by European data protection authorities. These binding corporate rules are a code for the transfer of data within our organization and companies and provide for safeguards of your personal data. Where  applicable, we have entered into model contractual clauses as adopted by the European Commission. These model contractual clauses were adopted by the European Commission to allow for the transfer of personal data to non-EEA countries that do not provide for an adequate level of data protection according to the European Commission. These model contractual clauses offer adequate safeguards for such transfer. And otherwise where applicable, your explicit consent will be requested for such proposed transfers.

Your rights:

We rely on legal grounds, for example the services and/or products requested by you, your (explicit) consent, our legal obligations and/or our legitimate interests to handle your Personal Data. If you ask us to stop handling your Personal Data in this way, we will stop unless we can show you that we have compelling grounds as to why our use of your Personal Data should continue. This may be to protect ourselves against any potential legal actions that may arise or to continue conducting our business in a fair and profitable fashion. Our use of legitimate interests will always be balanced against your right to privacy under the Data Protection Legislation.

You may send us your requests at the contact information set out below to exercise the rights to your Personal Data, which may include:

• You may revoke any (explicit) consent given to us with regard to the collection, processing and use of your Personal Data or the transfer of your Personal Data to countries out of the EEA at any time for the future and also generally request us to stop using and collecting your Personal Data;
• You have the right, at any time, to know whether your Personal Data has been stored and can consult us to learn about their contents and origin, to verify their accuracy or to ask for them to be supplemented, cancelled, updated or corrected, or for their transformation into anonymous format or to block any data held in violation of the law, as well as to oppose their treatment for any and all legitimate reasons;
• You have the right to request to obtain and reuse your Personal Data for your own purposes across different services; and/or
• You have the right to learn more details concerning the collection or processing of your Personal Data at any time.

We will only take instructions from you or your legal representative to effect or to alter your Personal Data and we will protect your privacy when you contact us by asking specific and relevant questions to make sure we are speaking to you or your legal representative and not to an unauthorized person.

In principle, we will respond to your request in a reasonable timeframe, and in any event in less than 30 days. We will be glad to honor such a request, unless we are required to retain this Personal Data by law or to comply with our regulatory obligations.

We reserve the right to refuse to act on a request that is manifestly unfounded or excessive (for example because it is repetitive) and/or to charge a fee that takes into account the administrative costs for providing the information or taking the action requested, where the applicable Data Protection Legislation allows us to do so.

You have the right to lodge a complaint against us with a competent supervisory authority.

Changes to this Privacy Policy:

We may change this Privacy Policy at any time to ensure it always accurately reflects the way we collect, use and safeguard your Personal Data. Should we make any material changes to our Privacy Policy, we will notify you accordingly by posting them to the Website, and to other places that we deem appropriate. We encourage you to check the Website regularly and to read our Privacy Policy regularly in order to stay updated.

Should you object to any of the changes to this Privacy Policy, this may mean that you must cease using our services or discontinue our business relationships. And you therefore can ask us to stop processing and erase your Personal Data.

All prior versions of this Privacy Policy will be kept in an archive for your review upon request.

Contacting us:

We are responsible for this Privacy Policy.

If you have any concerns as to how your personal data is processed or would like to exercise one of your rights you can contact:  [ADD DETAILS]

E-mail:miao.zou@cimc.com/Longchao.pi@cimc.com
TEL:86 0512 6957 1087

You can write to us  using the address of:
No. 2, Gangwan Avenue, Shekou Industrial Zone
Shenzhen, Guangdong, China P. R. (518067)
Updated on [DATE], 2018