Privacy Policy

Protecting the personal privacy of every customer, vendor, and employee is important to (the “Company”, “we”, “us”). As a global organization, we aspire to provide a high level of privacy protection across all our services.

This privacy policy (the “Policy”), with an effective date of 8 April, 2020, serves as our commitment to you to protect the security and privacy of your personal data, and covers the following areas of privacy concerns:

This Policy does not apply to third-party applications, products, services, websites or social media features that may be accessed through links that we provide on our websites and interfaces. Accessing those links may result in the collection of information about you by a third party. We do not control or endorse those third-party websites or their privacy practices. We encourage you to review the privacy policies of such third parties before interacting with them.

Your privacy is of utmost importance to us. We render our products and services to you on the basis of your understanding of your data privacy rights.

This Policy will be made multi-language, and all language versions shall be valid. In case of any discrepancy between the English version and other language versions, the English version shall prevail.

Please read this Policy carefully. When visiting our website and using our services that link to or reference this Policy, you agree to be bound by the terms and conditions of this Policy.

What is your personal data?
Personal data is any information that relates to an identifiable living individual. Any piece of data—whether by itself or used in conjunction with other pieces of data in a data controller’s possession—that can be used to identify you is considered your personal data. The processing of your personal data is governed by applicable privacy laws.

What role do we play in processing your personal data?
We are the data controller with respect to processing your data. This means that we decide how your personal data is processed and for what purposes. We know that you care about how your personal data is used and shared, and we appreciate your trust that we will do so carefully and sensibly. For more information, you can contact us using the channels set forth in the “Whom should I contact?” section of this Policy

When do we collect your personal data?
We can collect some of your data:

Our collection of personal data
The personal data we collect includes any and all data you provide us with when you: enter into contract with us, register an account with us, update or add your account information, enter our website, fill out our web forms, or give us data in any other way. You may choose not to provide us with any of your data, but that may hinder us from fully administering services to you if such services require your personal data. We use your personal data whenever we communicate with you, respond to your requests, manage your account, customize your service experience, improve our products and services, and personalize marketing activities. We may communicate with you through mail, email, or telephone. We will send you strictly service-related announcements or information on rare occasions, when it is necessary to do so.

Use of Google Analytics
Our website uses Google Analytics, a web analytics service provided by Google, Inc. (“Google”). Google Analytics uses cookies or IP addresses to help us monitor and analyze how users use our website site and our services. The information generated by cookies or IP addresses about your use of the website will be transmitted to and stored by Google on servers. Google will use this information on our behalf for the purpose of evaluating your use of the website, compiling reports on website activity, and providing us other services relating to website activity and internet usage. The IP address that your browser conveys within the scope of Google Analytics will not be associated with any other data held by Google. You may refuse the use of cookies by selecting the appropriate settings on your browser, however please note that if you do this you may not be able to use the full functionality of this website. You can also opt out from being tracked by Google Analytics by downloading and installing:

Use of Location Data
For the best User Experience, you may decide to use our Mobile Applications for Googles Android or Apples iOS operating systems. By installing the “MY SPERO” application on your device we use your device’s location data for better interaction to remotely control and detect the wireless device. The location feature may run in the background to better suit the applications availability of products within range of your mobile device. We will not disclose or use your location data for marketing and advertising purposes

Use of opt-in/subscription
You have a choice of whether or not you want to receive marketing communication materials from us, and how you want to receive these notifications. These materials detail marketing activities from us related to product solutions, services, and other helpful business content. You can manage your preferences by:

If you no longer wish to receive these communications from us, please follow the opting out or “unsubscribe” instructions provided in the link at the bottom of our marketing communications emails, or update your account settings.

How do we process your personal data?
We comply with our obligations under applicable privacy laws by: keeping personal data up to date; storing and destroying it securely; collecting and retaining only the necessary data that we need to provide you with service; protecting personal data from loss, misuse, unauthorized access, and disclosure; ensuring that appropriate technical measures are in place to protect personal data. The processing operations we perform on your data cover automated and non-automated means of collecting, recording, organizing, structuring, storing, altering, retrieving, using, transmitting, disseminating or otherwise making available, aligning or combining, restricting, and/or erasing your data. We use your personal data for the following purposes:

What is our lawful basis for processing your personal data?
In general, the lawful bases for us to process your personal data—for the various types of processing performed on your data—are, as applicable: processing as necessary for us to enter into and to perform our contract with you, or processing as necessary to pursue the legitimate interest of our Company or of the third parties. To know what types of processing your data undergoes, you can refer to “How do we process your personal data?” section of this Policy. We will collect, process, and use the personal data supplied by you only for the purposes communicated to you and will not disclose your data to third parties except under the circumstances of data disclosure described in the “Sharing your personal data” section below. Where we talk about our legitimate interest or that of third parties, such legitimate interest can include:

Processing of certain personal data
In accordance with the applicable privacy laws, we currently do not collect or process the following categories of data relating to you: your racial or ethnic origin, political opinions, religious beliefs, trade union membership, health data, genetic data, biometric data. If we had to process this type of data, we would always request your prior explicit consent.

Necessity to provide us data
You are not under any obligation to provide us any personal data. As noted below, the choice is yours. However, please note that without certain data from you, we may not be able to undertake some or all of our obligations to you under our service contract with you, or adequately provide you with our full range of services. If you would like to obtain more details about this, you can contact us using the channels set forth in the “Whom should I contact?” section of this Policy.

Sharing your personal data
Your personal data will be treated as strictly confidential, and will be shared only with the categories of data recipients listed below. We will only share your data with third parties outside of the Company with your consent, and you will have an opportunity to choose for us not to share your data. We may disclose your personal data to:

We may provide you with opportunities to connect with third-party applications or services. If you choose to use any such third-party applications or services, we may facilitate sharing of your information with your consent. However, we do not control the applications or services of those third parties or how they use your information, and your use of such applications and services is not governed by our Privacy Policy. Please review the terms and the privacy policies of those third parties before using their applications or services. Most of the advertisements which are sent to your web browser are made by us. However, we also allow other companies, called third-party ad servers or ad networks, to provide advertisements on our website. These companies may also send cookies to your computer. If an advertiser asks our website to show advertisements to certain visitors and you respond to that ad, the network advertiser or ad-server may think you as of the targeted audience they are trying to reach. The personal information you disclose to other parties such as network advertisers, third-party ad servers, or other websites from the Internet are protected by their respective privacy policies. The privacy policies of different network advertisers or third-party ad servers are not bound to this Policy, and our website is not responsible for these privacy policies. We will display your personal data and account activity in your profile page and elsewhere on our service portals according to the preferences you set in your account. You can review and revise your profile information at any time. Please consider carefully what information you disclose in your profile page and your desired level of anonymity. In your profile page, we will also display your device information as well as provide the network connection information for the devices to the applications that connect to your devices.

How long do we keep your personal data?
We keep your personal data for no longer than reasonably necessary for the given purpose for which your data is processed. If you will provide us, or have provided us, consent for us to process your data, we will process your data for no longer than your consent is effective. Notwithstanding the above, we may retain your personal data as required by applicable laws and regulations, as necessary to assist with any government and judicial investigations, to initiate or defend legal claims or for the purpose of civil, criminal, or administrative proceedings. If none of the above grounds for us to keep your data apply, we will delete and dispose of your data in a secure manner according to our Privacy Policy.

Privacy of data subjects under the age of 16
Our products and services are not targeted to persons under the age of 16. We do not knowingly collect or process personal data from persons under the age of 16. Please note that if you are under the age of 16, you should not buy or use our products or services, and we will not be liable for any losses or damages incurred by the unauthorized disclosure or processing of personal data under the age of 16.

Your rights and your personal data
Unless subject to an exemption under applicable privacy laws, you have the following rights with respect to your personal data:

After receiving your request, we will evaluate your request and inform you how we intend to proceed with your request. Under certain circumstances, in accordance with applicable privacy laws and regulations, we may withhold access to your data, or decline to modify, erase, port, or restrict the processing of your data. Please be advised that if you exercise the rights to erase data, restrict or object to our processing, or to withdraw your consent, we may not be able to continue providing our services to you if the necessary data is missing for processing.

Transfer, storage, and processing of data abroad
As noted in the “Sharing your personal data” section of this Policy, as a globally operating company, we may share your information with our affiliate companies or third parties. Please refer to the “Sharing your personal data” section of this Policy for the recipients of your data and the reasons for our provision of your data to them. Where such entities are located in other countries and jurisdictions, we will therefore be transferring your personal data outside of the European Economic Area. In making such data transfers, we make sure to protect your personal data by applying the level of security required by applicable privacy laws. Where we transfer your data to a country or jurisdiction that cannot guarantee the required level of protection as required by applicable privacy laws, we have enhanced our IT security measures and have entered into Standard Contractual Clauses (SCCs) with the transferee to require security obligations on the transferee, both of which are intended to increase the protection of your personal data. SCCs are one of a number of “appropriate safeguards” under the applicable privacy laws that enable the transfer of personal data concerning data subjects within the European Economic Area to jurisdictions that have not been designated by the European Commission as possessing an adequate level of data protection. You may request a copy of such SCCs from us, or inquire about transfers of your information, by providing your request to the contact window set forth in the “Whom should I contact?” section of this Policy.

Further processing
If we wish to use your personal data for a new purpose not covered by this Policy, then we will provide you with a new policy explaining this new use prior to commencing such further processing for a new purpose. This new policy sets out the relevant new purpose and processing conditions. In such a case, we will find a lawful basis for further processing, and whenever necessary, we will seek your prior written consent to such further processing.

We protect your data using technical measures to minimize the risks of misuse, unauthorized access, unauthorized disclosure, loss or theft, and loss of access. Some of the safeguards we use are data pseudonymization, data encryption, firewalls, and data access authorization controls. We take our data security very seriously. Therefore the security mechanisms used to protect your data are checked and updated regularly to provide effective protection against abuse. The servers through which we collect your information are usually encoded using the encryption module of your browser, and are certified by renowned institutions for international encryption technique. If necessary, we use Secure Sockets Layer (SSL) encryption to protect your personal information. Moreover, we have put in place additional and comprehensive state-of-the-art security measures every time your data are accessed through the internet. Firewalls prevent unauthorized access. Diverse encryption and identification layers protect your data from intrusion or disclosure to third parties during data transfer. Furthermore, we internally use sophisticated encoding methods in order to prevent decoding by unauthorized persons. Moreover, an electronic identifier is generated during data transfer to safeguard your information. For your confidentiality and security, we use IDs and passwords to secure your personal information. It is important for you to protect your ID, password, or any personal information. Do not disclose your personal information, especially your password, to anyone. When you are finished using our services, please do not forget to log out from your account. If you share a computer, whether in a public or private setting, be sure to sign off and close your browsers when finished using a shared computer. If you believe that the security of your data has been compromised, or if you would like more information on the measures we use to protect your data, you can contact us using the channels set forth in the “Whom should I contact?” section of this Policy.

What are your choices?
You have the choice to allow us to collect and process your data. The collection and processing of your personal data is neither a statutory nor a contractual requirement, although as noted above, we will be unable to provide you with certain services without the necessary data. If you are dealing with us online, note that most browsers will inform you how to prevent your browser from accepting new cookies, how to receive notifications whenever you receive a new cookie, and how to disable cookies. Additionally, you can disable or delete the data used by browser add-ons, such as Flash cookies, on your browser or on the website of its manufacturer. You can always choose not to provide us with your data. In case we may need such data to process your requests, we will inform you of our constraints. To the extent that you have consented to our processing of your data, you can choose to discontinue our processing at any time. You can choose to request a copy of the personal data we store and process regarding you. You can choose to add or update data that you have provided us with. You can choose to erase your data, or choose to restrict our processing of your data instead. You can choose to port your data to a third party under the conditions stated above. You can choose to object to our processing of your data. You can inform us of your choices or request on any data processing aspect listed above using the channels set forth in the “Whom should I contact?” section of this Policy. In summary, what we are allowed to do with your data—with limited exceptions under applicable privacy laws—is up to you. However, in the event that you choose not to let us further process your data, your choice may affect the delivery of our obligations or services to you. In this case, we will inform you of our constraints.

Whom should I contact?
If you have any questions about this Privacy Policy, or if you would like to exercise any of your rights, or if you have any complaints that you would like to discuss with us, please send us a signed and dated request. State your request clearly and accurately within the first sentence of your query. You may contact us through the following methods: by post to: Duomondi International Development Co., LTD. Data Protection Manager Flat D, 19F, Roxy Industrial Centre, 59-66 Tai Lin Pai Road, Kwai Chung, NT, Hong Kong