Applies to the website www.rightwayasia.com, including the dedicated areas in which the user can freely and expressly provide a series of data concerning him/her in order to contact RIGHTWAY ASIA (or send requests) is provided pursuant to and in accordance with Article 13 of the EU General Data Protection Regulation (hereinafter “GDPR”) and explains how the personal information provided by the user may be used, shared, accessed, modified or deleted. The information is also based on Recommendation No. 2/2001 on minimum requirements for on-line data collection in the European Union, adopted on 17 May 2001 by the Article 29 Working Party.
The security measures applicable to this Website have been defined and developed to ensure that the processing of the user’s personal data is carried out in compliance with the principles of lawfulness, correctness, transparency, purpose limitation and storage, data minimisation, accuracy, integrity and confidentiality, in accordance with the national and European regulations in force.
1. Data controller
The data controller is RIGHTWAY ASIA, with registered office in18/F, 1808 Beverly House, 107 Lockhart Road, Hong Kong VAT 37021466453251. The updated list of Data Processors and persons authorised to process data can be found at the registered office of the Data Controller. For any further information or clarification, RIGHTWAY ASIA may be contacted at the address indicated, or at the e-mail address firstname.lastname@example.org
2. Personal data being processed
2.1. Navigation data
The processing of personal data of users who visit and consult the Site is limited to so-called navigation data, the transmission of which is necessary for the operation of computer systems and programs necessary for the operation of the Site, but which by their very nature could, in association with other data, allow the identification of users.
These include IP addresses or the names of the computers used by users who connect to the Site, the URI (Uniform Resource Identifier) addresses of the resources requested, the time of the request, the method used to submit the request to the server, the size of the file obtained in response, the numerical code indicating the status of the response given by the server (successful, error, etc.) and other parameters relating to the operating system and the computer platform used by the user.
This data is used for the sole purpose of obtaining anonymous statistical information on the use of the Site and to check its correct operation. This data may also be used to ascertain responsibility in the event of computer crimes against the Site in accordance with the procedures in force at the competent authorities.
Except in this case, navigation data are only temporarily stored in compliance with the applicable legislation.
2.2. Data provided voluntarily by the user
No registration is required to access the contents of the Site. However, there are services on the Site for which you must provide your data.
If RIGHTWAY ASIA acquires information and personal data, it will inform you in advance of the purpose for which such data is required and the manner in which it will be used.
By way of example, if the User decides to contact RIGHTWAY ASIA through the contact forms, personal data such as name and surname, telephone number, e-mail address and any other information that the User agrees to provide may be requested. The User, in this case, consents to their use for the purpose of responding to requests for information, quotations, or any other nature indicated in the header of the form.
Where necessary, RIGHTWAY ASIA will obtain your specific consent to the relevant use of your data.
3. Data of users under the age of 18
The Site is not aimed at minors and RIGHTWAY ASIA does not knowingly collect personal data from them. In the event of the accidental recording of any information about minors, RIGHTWAY ASIA will delete it in a timely manner at the request of users.
4. Legal basis and purpose of processing
In some cases it is necessary to process your personal data in order to perform our contract with you in relation to your use of the site.
- To allow access to the Website and enable its proper use by the User.
- Process User requests and provide information.
We collect and process personal data to improve and monitor the efficiency of the Site and offer up-to-date services.
- Improving the efficiency of the Site.
- To carry out statistical analysis on the efficiency and operation of the Site.
- To ensure the best possible User experience when browsing the Site.
- Manage and respond to requests for applications submitted via the Site, for which we invite you to read the relevant notice.
Fulfilment of legal obligations
We may use the data you provide to comply with requests from the authorities and for the fulfilment of security-related obligations.
- In some cases we may need to use your information to manage and resolve legal disputes and to ensure the security of the Site and its users.
With your consent we may carry out marketing activities.
- With your consent we may send you commercial communications to update you on our products and services and to let you know about our latest news.
With your consent we may carry out profiling on site activity.
5. Recipients of personal data
- Subjects acting as Data Processors, such as, by way of example: persons, companies or professional firms providing assistance and consultancy to RIGHTWAY ASIA in accounting, administrative, legal, tax and financial matters; subjects delegated to perform services of a technical nature; credit institutions and insurance companies;
- people authorised by RIGHTWAY ASIA to process personal data for activities strictly related to the provision of services, who have an appropriate legal obligation of confidentiality;
- police forces, armed forces and other public administrations in order to fulfil their obligations under laws, regulations and national or European legislation and to agencies or professionals to collect debts (e.g. outstanding debts owed to us) or to enable RIGHTWAY ASIA to defend itself in court, for example in the event of a breach of the network by users;
- only with the specific consent of the user, personal data may be communicated to RIGHTWAY ASIA business partners or third parties (subject to the adoption by the latter of data security and protection criteria in line with current legislation) for marketing and profiling purposes as described above.
6. Transfer of personal data
RIGHTWAY ASIA does not transfer personal data to third countries or international organisations. However, it reserves the possibility of using cloud services. In this case, the service providers will be selected from among those who provide adequate guarantees, as provided for in Article 46 GDPR 679/16. The processing, therefore, will take place in accordance with one of the methods permitted by current law, such as, for example, the adoption of Standard Clauses approved by the European Commission, the selection of subjects adhering to international programmes for the free movement of data, (e.g. EU-USA Privacy Shield) or operating in countries considered safe by the European Commission.
7. Storage of personal data
The information systems and computer programmes used by RIGHTWAY ASIA are configured in such a way as to minimise the use of personal and identification data; such data are processed only for the achievement of the specific purposes from time to time pursued; in any case, the criterion used to determine the storage period is based on compliance with the terms allowed by applicable laws and the principles of minimisation of processing and rational management of archives.
8. Rights of the data subject
Pursuant to Articles 15 et seq. of the Regulations, the user has the right to ask RIGHTWAY ASIA , at any time, for access to his/her personal data, to rectify or erase them, or to object to their processing pursuant to Article 21 of the GDPR. He/she also has the right to request the restriction of processing in the cases provided for by Article 18 of the GDPR, as well as to obtain in a structured, commonly used and machine-readable format the data concerning him/her, in the cases provided for by Article 20 of the GDPR.
In any case, the user is always entitled to lodge a complaint with the competent supervisory authority (Garante per la protezione dei dati personali), pursuant to art. 77 of the Regulation, if he/she believes that the processing of his/her data is contrary to the legislation in force.
RIGHTWAY ASIA therefore invites its users to regularly visit this section in order to be updated on the data collected and the use made of it by the Data Controller.