Data protection policy

It is recommended that persons visiting the website available at www.tme.hk read this Privacy Policy before submitting any personal data and/or filling out any online forms available at the website. This policy specifies which personally identifiable information can be collected and used. Furthermore, this policy also takes into account other important issues related to the privacy of natural persons.

Privacy Policy

Table of contents

1. General provisions
2. Collection of personal data
3. Use of personal data
4. Rights related to the processing of personal data
5. Retention of personal data
6. Data Protection Officer
7. Data safety
8. Data collection via cookies
9. Profiling
10. Free newsletter subscription (TME Newsletter)
11. Links to external websites
12. Final provisions

1. General provisions

The purpose of this Policy is to:

ensure that you know what personal data we collect about you, what serves as the basis of this collection, for what reasons we collect and use this data, and who we share it with;
explain how we use the personal data you share with us, to ensure you get the best experience using our website; and
clarify your rights and preferences pertaining to the personal data we gather, as well as the ways in which we protect your privacy.

1) Transfer Multisort Elektronik Sp. z o.o. with its registered office in Łódź at ul. Ustronna 41, 93-350 Łódź, Poland, entered in the Company Register by the District Court for Łódź-Śródmieście, XX Department of the National Court Register (KRS), under KRS number 0000165815, with initial share capital of PLN 3,300,000.00, NIP 729-010-89-84, REGON 473171710 (hereinafter referred to as "the Company"), and its subsidiaries comply with the rules of preserving the privacy of natural persons and protect their personal data with due diligence.

This Privacy Policy applies to all information collected and used by Transfer Multisort Elektronik Sp. z o.o. and its subsidiaries, and it addresses, in particular, the services offered by the Company via website available at www.tme.hk –hereinafter referred to as a "TME website."

2) This Privacy Policy does not apply to third party websites and services that can be accessed via links shared on the aforementioned TME website.

3) Within the meaning of this Policy, the term "Customer" means a natural person visiting the TME website and/or using the services provided by the Company.

2. Collection of personal data

1) In accordance with the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (hereinafter referred to as GDPR), Transfer Multisort Elektronik sp. z o.o., ul. Ustronna 41, 93-350 Łódź (hereinafter referred to as "TME") is the Data Administrator, and consequently the party responsible for determining the purposes and methods of processing of personal data of customers, potential customers, and other natural persons using the https://www.tme.hk website.

2) We process your personal data because it is necessary to perform a contract we sign with you via our website (https://www.tme.hk), i.e. to provide a service (compliant with Article 6 (1) (b) of GDPR). Furthermore, we process personal data for the following purposes:

registering you in the ordering system and ensuring proper user service, including providing you with product offers and completing your orders (compliant with Article 6 (1) (b) of GDPR);
possibly contacting you and responding to issues/questions you report in a form (compliant with Article 6 (1) (a) of GDPR);
contacting you and answering questions regarding product offerings you submit in a form (compliant with Article 6 (1) (a) of GDPR);
processing claims and complaints (compliant with Article 6 (1) (c) of GDPR);
pursuing claims related to an insurance contract (compliant with Article 6 (1) (f) of GDPR) where the right to pursue claims is a legitimate interest;
archiving purposes (compliant with Article 6 (1) (c) of GDPR);
statistical purposes (compliant with Article 6 (1) (f) of GDPR) where having statistical information about our activities – enabling us to streamline our business – is a legitimate interest of the Data Controller.

Furthermore, we may process personal data for marketing purposes, i.e. promoting our products and services. If we do this without using electronic means of communication, the legal basis for those activities is Article 6 (1) (f) of GDPR where conducting marketing activities is a legitimate interest of the Data Controller. However, if we use electronic means of communication for this purpose, such as e-mail or phone, then due to other applicable laws we only process personal data after obtaining your consent (compliant with Article 6 (1) (a) of GDPR).

3) Personal data of Customers of the Company is processed and protected in accordance with provisions of the law governing protection of personal data, including but not limited to GDPR and the Personal Data Protection Act. The Company does not transfer, sell, or rent collected personal data to other persons or institutions, except when it is necessary to fulfil obligations under applicable laws or after obtaining a consent to those actions from the data subject. The Company may transfer personal data to third parties in accordance with conditions laid down in applicable laws.

4) When signing up for the service via the registration form, each Customer provides their full name, address of residence, email address, phone number, country of residence, town, postal code, and language preferences. Providing this information is voluntary, however providing full name and address of residence is necessary for the conclusion of a sales agreement with the Company.

5) Each Customer enters a login and a password protecting their service account. Each Customer should keep their login and password safe from unauthorised persons.

3. Use of personal data

1) Personal data may be transferred to other parties, also to parties that will process it on their own behalf, including but not limited to:

parties conducting postal or courier activities;
banks and payment intermediaries (depending on the payment method chosen by the Customer) – for undue payment recovery purposes;
payment intermediaries (if the Customer chooses this payment method) – for the purpose of making payments;
government authorities or other entities entitled by law, for the purposes of performing our obligations (tax offices, law enforcement agencies, etc.);
parties managing our IT systems (hosting companies, IT service providers);
parties providing us with legal counsel, accounting, tax, claim collection, and advisory services;
Shenzhen TME Electronic Trading Company Ltd. – Company’s Chinese subsidiary, which supports Company in handling any activities undertaken by customers through Company’s website at www.tme.hk, including account registration, preparing quotations, processing orders, tracking shipments and potential complaints regarding ordered products.

2) Data collected via a Customer directly contacting the Company through the website is used solely for the purposes of communications with that Customer and responding to their queries.

4. Rights related to the processing of personal data

1) You have the right to access, correct, and transfer your data, restrict its processing, object to its processing, or withdraw your consent at any time without affecting the lawfulness of processing that was already performed on the basis of consent prior to its withdrawal (if the processing is consent-based).

Moreover, should you decide that our processing breaches the provisions of GDPR, you have the right to submit a complaint to a data protection authority (the Personal Data Protection Office).

5. Retention of personal data

We will retain your personal data for the duration of a contract (performance of services) and after its dissolution:

data included in contracts – stored until the limitation period for contract claims (up to 10 years from the date of contract completion);
for the purposes required under applicable law, in particular the obligation to retain accounting documentation, issue invoices, etc.;
warranty and complaint-related documentation shall be stored for 1 year after the expiration of a warranty or clearing a complaint;
data transferred in a contact form – for the limitation period of possible claims (up to 3 years);
data used for marketing purposes:
- when processing data on the basis of consent: until withdrawal of such consent or end of marketing activities;
- when processing data on the basis of legitimate purposes of TME: until submittal of an objection to processing or end of marketing activities.

6. Data Protection Officer

1) You can contact the Data Protection Officer on matters concerning the protection of your personal data via email at [email protected] or by sending a letter to our headquarters:
Marcin Gadzki
Transfer Multisort Elektronik sp. z o.o.,
ul. Ustronna 41, 93-350 Łódź (Polska)

7. Data safety

1) The Company and its subsidiaries use appropriate security measures to ensure the collected personal data is safe from unauthorised access, alteration, public disclosure, and destruction. Those security measures include both technical solutions included within the service itself, such as e.g. appropriate encryption of data transmitted over the Internet, strict control of physical access to the computers and data storage media containing personal data, and application of and adherence to proper procedures of storing and handling personal data. All persons processing personal data of Customers for purposes related to the TME website have appropriate permissions issued by the Data Administrator and undergo regular data protection training.

2) The Company creates backup copies of personal data of its Customers, and may use other similar measures in order to protect that data from accidental damage or destruction.

3) Credit card and online payments are handled by PayPal and PayU. Those services are responsible for all data disclosed in their forms, which are also protected with appropriate technical safeguards.

8. Data collection via cookies

1) Some pages within the TME website may use cookies – small text files sent to the hard drive of the Customer device that identify a particular Customer in a way that lets us collect information about their visits to the website, as well as store their preferences such as e.g. language settings of the login page. Cookies do not enable processing or storage of personal data. The same applies to all persons visiting the TME website who are not registered users.

2) Cookies are used to adjust the TME website's contents to preferences of each user. They are also used to generate anonymous statistics that let us understand the ways in which users use our website. This understanding allows us to improve the website's structure and content without personally identifying its users. Cookies also enable analysis of which components of our website are the most interesting to its users.

Cookies can be used during remarketing activities. Ads in the form of an image or text, based on previously saved user preferences, are displayed on other websites to people who have previously visited a given page.

When advertising online - TME ads online are provided by third parties. TME and third party providers, , use cookies to target ads based on previous visits of the ad recipient on the TME website.

3) You can disable cookies in the options section of your web browser at any time, but doing this may prevent you from using the TME website.

By default, web browsing software accepts placing cookies on the end device. However, you can change your web browser settings to block automatic support of cookies, or to inform the user every time a cookie is sent to the device. Information on the support for cookies and available options can be also found in the Settings section of your app (web browser).

However, you should remember that restricting the use of cookies may have a negative impact on selected functionalities of the website. To learn more about cookies used by TME and manage the settings, click here.

9. Profiling

Your personal data will be processed in an automated way (including profiling), however this will not cause any legal or other serious repercussions for you.

10. Free newsletter subscription (TME Newsletter)

1) Newsletter is a free of charge service which provides Customers who added themselves to a subscribers list with information on the offering of the Company and its subsidiaries, events, and any other information related to the trading business of the Company and its subsidiaries, by regular distribution of selected contents in the form of an electronic letter.

2) To sign up to a newsletter subscribers list, you need to check an appropriate box on the homepage of the TME website to provide consent to receiving a free newsletter ("Add"), and enter your e-mail address. Alternatively, you can check an appropriate box in the registration form. Selecting the box is not required. Information collected this way is added to the mailing list.

3) The Customer who decides to subscribe to the TME Newsletter agrees to receive marketing materials via electronic means in accordance with Art. 8.1 of the Act of 18 July 2002 on provision of services by electronic means (Journal of Laws of 2002, No 144, Item 1204, as amended) in the form of TME Newsletter.

4) Contact information of Customers who signed up to the service in order to gain access to the Newsletter is used exclusively for the purpose of sending Newsletters to those Customers.

5) The Customer can at any time resign from the Newsletter service by checking an appropriate box on the homepage of the TME website to revoke consent to receiving a free newsletter ("Remove").

11. Links to external websites

The TME website may include links to different websites, provided for the information and convenience of the Customer. The Company is not responsible for any information provided nor Privacy Policies applied by those websites. The Customer should be aware that such websites are separate from the TME website, and each time should verify on their own the Policy of each website visited with the use of any such link.

12. Final provisions

1) The Company may introduce changes to this Privacy Policy at any time. Every time a new Privacy Policy is published on the TME website, it becomes binding and applicable to all data collected in relation to Customer's activities on the TME website taking place after the publication of such revised Privacy Policy on an appropriate page of the TME website.

2) Should you have any additional questions related to the Privacy Policy, please contact our Data Protection Officer at: [email protected] or via traditional mail:

Marcin Gadzki

Transfer Multisort Elektronik sp. z o.o.,

ul. Ustronna 41, 93-350 Łódź (Polska)

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