Privacy Policy and Disclaimer

Heteng New Energy Auto Service (HK) Limited

Personal Data and Privacy Statement

Our Commitment to Protecting Your Privacy

Heteng New Energy Auto Service (HK) Limited (“we”, “us”, “our” or “the Company”) thanks you for your interest in the Company and our products and services.
Your privacy is very important to us. By clearly explaining our privacy policy, we hope to help you feel assured when browsing our website (www.heteng.com.hk) and using our products and services.

By browsing this website or any of its pages, or using our products and/or services, you agree to the terms set out in this policy.

1. General

1.1 This statement sets out the personal data policy adopted by Heteng New Energy Auto Service (HK) Limited (“the Company”) under the Personal Data (Privacy) Ordinance (Chapter 486 of the Laws of Hong Kong) (“the Ordinance”).
1.2 Unless otherwise stated, the terms used in this statement shall be interpreted in accordance with the Ordinance.

2. Purposes of Collecting Personal Data

2.1 Any personal data provided to the Company by you or on your behalf is provided voluntarily. Such provision shall be deemed to authorise the Company to collect, retain, update and use your personal data for the purposes specified in Clause 2.2 below.
2.2 Personal data provided to the Company by you or on your behalf from time to time, together with other personal data concerning you collected and retained by the Company, will be used for the following purposes:
(a) Arranging vehicle instalment payments and/or leasing;

(b) Providing vehicle maintenance, repairs and other after-sales services;

(c) Providing you with other products, facilities and services from time to time;

(d) Collecting outstanding amounts payable by customers;
(e) Providing information to the Company’s authorised service agents for maintenance, repairs and other after-sales services;
(f) Marketing any products or services offered by Heteng New Energy Auto Service (HK) Limited and its subsidiaries, related companies and associated companies;
(g) Verifying information by comparing the personal data you provide with other information concerning you held by other members of Heteng New Energy Auto Service (HK) Limited;
(h) Conducting statistical surveys, market surveys and research;
(i) Conducting financial audits;
(j) Fulfilling any other lawful purposes related to the purposes listed above; and
(k) Exercising any of the Company’s legal or other rights against you.

2.3 If the Company considers the personal data you provide insufficient, or is not satisfied with its authenticity and accuracy, the Company reserves the right to refuse or suspend processing your application or providing any services to you until it receives the required personal data.

2.4 For the purposes specified in Clause 2.2, the Company’s employees or persons engaged by the Company are authorised to access the personal data you provide.

3. Use of Personal Data

The Company will keep your personal data confidential. However, to fulfil the purposes described above under “Purposes of Collecting Personal Data”, the Company may provide such data to the following parties, whether located within or outside the Hong Kong Special Administrative Region (“Hong Kong”):
(a) Agents, contractors or third-party service providers supplying administrative, telecommunications, computer or other services to the Company and its customers;
(b) Agents authorised by the Company from time to time to process customers’ personal data;
(c) Business partners selected by the Company;
(d) Other members of the Company located within or outside Hong Kong;
(e) The Company’s auditors, advisers or legal advisers, whether located within or outside Hong Kong;
(f) Other persons who owe a duty of confidentiality to the Company; and
(g) Any actual or proposed transferee or assignee of the Company.

4. Confidentiality

4.1 The Company will take reasonable measures to keep the personal data you provide confidential and store it securely. The Company will also take reasonable measures to ensure that persons with access to such data are trustworthy, careful and suitably competent.
4.2 To comply with Hong Kong laws, the Company may disclose the personal data you provide to government departments or other regulatory authorities.

5. Special Provisions Concerning Personal Data Held through the Internet

5.1 When you interact with the Company through its website (www.heteng.com.hk), you will be deemed to have agreed to the terms and conditions set out in this statement.
5.2 The Company will take reasonable measures to ensure that personal data held through the website from time to time is stored safely and properly.
5.3 The Company may use cookies (small text files) on its website to:

(a) Enhance website security;

(b) Ensure that you complete the application process;
(c) Provide you with a personalised website experience; and
(d) Create a profile of your use of the website.
5.4 You may refuse cookies at any time through your internet browser settings.

6. Your Rights

6.1 If you object to the use of your personal data under Clause 2, or its provision or disclosure under Clause 3, please notify the Company in writing. The Company’s address is stated on the relevant forms or contracts signed between you and the Company. Upon confirming your request, the Company will cease using and/or providing or disclosing such data.

6.2 Unless you request the deletion of all personal data you have provided, you acknowledge that the Company may retain such data and continue providing marketing information to you, even if you have applied for a membership arranged by the Company or such membership has been cancelled or withdrawn, the warranty period for any products or services provided by the Company has expired, or the Company has completed the sale of products or provision of services, as applicable.

7. Requests for Access and Correction

7.1 You have the right to request access to and correction of your personal data in accordance with the Ordinance.
7.2 If you wish to correct any personal data, please notify the Company that collected the data in writing so that the relevant amendments can be made.
7.3 Enquiries concerning the collection of personal data, including requests for access and correction, should be sent to the address stated on the relevant forms or contracts signed between you and the Company, or to another address designated by the Company from time to time.
7.4 Under the relevant provisions of the Ordinance, the Company may charge a reasonable fee for processing a data access request, and you agree to pay such fee.

8. Use of Personal Data in Direct Marketing

The Company intends to use customers’ personal data for direct marketing. The Company may not use such data for this purpose without the customer’s consent, which includes an indication of no objection. Please note the following:
(i) The Company may use customers’ names, contact details, product and service portfolio information, transaction patterns and behaviour, spending preferences, financial background and demographic information held from time to time for direct marketing.

(ii) The Company will conduct direct marketing relating to the following goods, facilities, services and other marketing subjects:

(a) Brand events, motor shows, customer events, automotive services and products, automotive insurance services and offers, vehicle sales and after-sales services and offers, online shopping, and gift redemption;

(b) Loyalty, rewards and promotional programmes, and related services and products;
(c) Services and products offered by brands and business partners collaborating with the Company, including clothing and accessories, arts and culture, auctions, baby and childcare, banking and finance, beauty, concierge services, credit card services, renovation, education, electronic and electrical products, energy, engineering, entertainment, environmental protection, fashion, food and beverages, furniture and equipment, group buying, hygiene and health, hotels and catering, home-related services and products, information technology, insurance, jewellery and watches, laboratory services and scientific research, lubricants and petroleum, luxury goods, manufacturing, medical services, pets, planning and design, private clubs, professional services, property and real estate management, publishing and media, social networking, sports, telecommunications, transportation and logistics, travel, and weddings;
(d) Donations for charitable and/or non-profit purposes.
(iii) The above goods, facilities, services and marketing subjects will be provided or solicited by the Company and/or the following parties:
(a) Any subsidiary, related company or affiliated company of Heteng New Energy Auto Service (HK) Limited;
(b) Any third-party supplier of goods and/or services;
(c) Any third-party provider of rewards, loyalty, co-branded or promotional programmes; and
(d) Any charitable organisation.
(iv) In addition to conducting direct marketing itself, the Company intends to provide the above data to all or any of the persons specified in paragraph (iii) for use in their direct marketing of the relevant goods, facilities, services and marketing subjects. The Company may not provide such data to other persons for this purpose without the customer’s written consent, which includes an indication of no objection.
If a customer does not wish the Company to use their personal data, or provide it to other persons, for direct marketing as described above, the customer may notify the Company to exercise their right to opt out. The Company will cease using or providing such data for direct marketing without charging the customer a fee.
Customers may communicate their consent to the Company’s use or provision of their personal data for direct marketing to the Company’s Data Protection Officer, whose contact details appear below, or through another channel specified by the Company when collecting their personal data.

9. The Company’s Data Protection Officer

Requests for access to or correction of personal data, requests for information about the Company’s privacy policies and practices or the types of personal data it holds, and any related communications mentioned above should be addressed to:The Company intends to use customers’ personal data for direct marketing. The Company may not use such data for this purpose without the customer’s consent, which includes an indication of no objection. Please note the following:

Data Protection Officer

Units 1001–1004, 10/F, One Pacific Place
88 Queensway, Hong Kong
Email: denzacs.harmony@hexieauto.com
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