Privacy Policy
Learn how we collect, use, and protect your personal information
This Privacy Policy describes how Huizhou Kelin Industrial Development Co., Ltd. (operating as "CKY", "we", "us", or "our") collects, uses, and protects your personal data when you use our website. This policy is prepared in accordance with the Personal Data (Privacy) Ordinance (Cap. 486) of Hong Kong ("PDPO") and other applicable data protection laws.
By using this website, you acknowledge that you have read and understood this Privacy Policy and agree to the collection and use of information in accordance with this policy.
1. Information We Collect
1.1 Personal Data
When you submit a form or contact us through this website, we may collect the following personal data for the purpose of responding to your inquiries and providing you with information about our products and services:
- Name
- Email address
- Phone number (if provided)
- Company name (if provided)
- Any other information you include in your message or inquiry
1.2 Usage Data
We may automatically collect certain technical information when you visit our website, including:
- IP address
- Browser type and version
- Device information (operating system, screen resolution)
- Pages visited, time spent on pages, and navigation paths
- Referring website addresses
- Date and time of access
1.3 Data Storage Location and Cross-Border Transfer
Important Information:
Your personal data will be stored on secure servers located in Hong Kong (Alibaba Cloud Hong Kong data center - oss-cn-hongkong). We use content delivery network (CDN) services that may cache your data across different regions to optimize website performance.
If it becomes necessary for business purposes to transfer your data outside of Hong Kong (including to the People's Republic of China or other jurisdictions), we will:
- Comply with all applicable data protection laws, including PDPO Section 33 requirements
- Implement appropriate safeguards such as standard contractual clauses or equivalent mechanisms
- Provide you with separate notice and, where required by law, obtain your consent before such transfer
- Ensure that the recipient jurisdiction provides adequate protection for your personal data
2. How We Use Your Personal Data
2.1 Primary Purposes
We use your personal data only for purposes directly related to the purpose for which it was collected, in accordance with PDPO Data Protection Principle 3:
- Inquiry Response: To respond to your inquiries, questions, and requests submitted through our contact forms
- Service Provision: To provide you with information about our audio products and services that you have specifically requested
- Business Communication: To communicate with you regarding your requests and maintain our business relationship
- Website Improvement: To analyze website usage patterns and improve our website functionality, security, and user experience (using anonymized data where possible)
- Security and Compliance: To maintain website security, prevent fraud, detect and respond to security incidents, and comply with legal obligations
2.2 Direct Marketing (Requires Separate Consent)
Marketing Communications
We will only use your personal data (name, email address, and phone number) for direct marketing purposes (such as sending promotional emails about our new products, special offers, or events) if we have obtained your explicit prior written consent in accordance with PDPO Section 35G.
If you provide consent to receive marketing communications, you have the right to:
- Opt-out at any time by clicking the "Unsubscribe" link in our marketing emails
- Withdraw your consent by contacting us at info@ckychina.com or dpo@ckychina.com
- Request that we cease using your data for direct marketing, free of charge and without adverse consequences
We will not use your personal data for purposes other than those stated above without obtaining your separate consent or as otherwise permitted or required by law.
3. Cookies and Tracking Technologies
3.1 What Are Cookies?
Cookies are small text files placed on your device when you visit our website. They help us understand how users interact with our website and improve your browsing experience. When you first visit our website, you will be presented with a cookie consent banner on our homepage where you can manage your cookie preferences.
3.2 Types of Cookies We Use
3.3 Google Analytics
We use Google Analytics to analyze website traffic and user behavior. Google Analytics uses cookies to collect information about your use of our website. This information is transmitted to and stored by Google on servers located in the United States and other countries. Google will use this information to evaluate your use of the website, compile reports on website activity, and provide other services relating to website activity and internet usage.
For more information on how Google uses data, please visit: How Google uses data when you use our partners' sites or apps
3.4 Managing Cookies
You can control and manage cookies through:
- Our Cookie Consent Banner: When you first visit our website, you can accept or decline non-essential cookies through the banner displayed on the homepage
- Browser Settings: You can configure your browser to refuse all or some cookies. Please note that disabling cookies may affect the functionality of this website
For more information on how to manage cookies in your browser, please refer to:
4. Data Sharing and Disclosure
We Never Sell Your Data
We do not and will not sell, trade, rent, or otherwise commercialize your personal data to third parties.
4.1 Service Providers (Data Processors)
We may share your personal data with carefully selected third-party service providers who assist us in operating our website and providing our services. These service providers act as data processors and are contractually obligated to:
- Process your data only on our instructions and for specified purposes
- Implement appropriate technical and organizational security measures
- Maintain confidentiality and data security
- Not use your data for their own purposes or disclose it to others without authorization
- Delete or return data upon termination of services
Categories of service providers include:
- Cloud Hosting Services: Alibaba Cloud (Hong Kong) for website hosting and data storage
- Content Delivery Network (CDN): For website performance optimization and content caching
- Email Service Providers: For processing and delivering contact form submissions and email communications
- Analytics Providers: Google Analytics for website usage analysis (with data anonymization where applicable)
4.2 Legal Requirements
We may disclose your personal data if required to do so by law or in response to valid requests by public authorities, including to:
- Comply with a legal obligation, court order, subpoena, or regulatory requirement
- Protect and defend our rights, property, or safety, or that of our users or the public
- Prevent or investigate possible wrongdoing, fraud, or security incidents in connection with our services
- Cooperate with law enforcement or regulatory authorities when legally required
4.3 Business Transfers
In the event of a merger, acquisition, reorganization, asset sale, or similar business transaction, your personal data may be transferred to the successor entity. We will provide notice before your personal data is transferred and becomes subject to a different privacy policy, and you will be given the opportunity to withdraw consent if required by law.
5. Data Security
We are committed to protecting your personal data and have implemented appropriate technical and organizational security measures in accordance with PDPO Data Protection Principle 4 to prevent personal data from being accidentally or deliberately compromised.
Encryption in Transit
We use industry-standard SSL/TLS encryption (TLS 1.2 or higher with AES-256 or equivalent) to protect your data during transmission between your browser and our servers.
Encryption at Rest
Your personal data is stored on secure servers with encryption at rest (AES-256) and restricted physical and logical access controls to prevent unauthorized access.
Access Controls
We implement role-based access controls (RBAC), multi-factor authentication (MFA) for administrative access, and maintain detailed access logs to prevent unauthorized access to personal data.
Regular Security Audits
We conduct regular security assessments, vulnerability scans, and penetration testing to identify and address potential security risks and maintain the integrity of our systems.
5.1 Data Breach Notification
Data Breach Protocol:
In accordance with PDPO Sections 64B-64D and the guidance issued by the Privacy Commissioner for Personal Data (PCPD), in the event of a data breach that meets the criteria for notification, we will:
- Notify the Privacy Commissioner for Personal Data as soon as practicable, and in any event no later than 5 business days after becoming aware of the data breach
- Notify affected data subjects without undue delay if the breach is likely to result in serious harm to the affected individuals
- Provide details including the nature of the breach, categories and approximate number of affected individuals, potential consequences, and measures taken or proposed to address the breach
- Implement remedial measures to mitigate harm and prevent future occurrences
- Maintain records of the breach and our response for compliance and audit purposes
Important: While we implement robust security measures designed to protect your personal data, no method of transmission over the internet or electronic storage is 100% secure. We cannot guarantee absolute security but will use commercially reasonable efforts to protect your personal data in accordance with industry best practices and applicable legal requirements.
6. Data Retention
In accordance with PDPO Data Protection Principle 2(2), we retain your personal data only for as long as necessary to fulfill the purposes for which it was collected, comply with legal obligations, resolve disputes, and enforce our agreements.
6.1 Retention Periods
| Data Type | Retention Period | Reason |
|---|---|---|
| Contact Form Submissions | 12 months from date of submission | To respond to inquiries and maintain business records for customer service purposes |
| Email Correspondence | 24 months from last communication | To maintain business relationship history and provide continuity of service |
| Website Analytics Data | 26 months from collection (Google Analytics default) | To analyze trends, improve website performance, and understand user behavior |
| Cookie Consent Records | 12 months from withdrawal or last interaction | To demonstrate compliance with cookie consent requirements |
| Marketing Consent Records | Duration of consent + 12 months after withdrawal | To demonstrate compliance with PDPO Section 35G requirements |
| Access/Correction Requests | 7 years from request completion | Legal compliance, audit purposes, and to respond to potential regulatory inquiries |
6.2 Secure Disposal
Upon expiration of the retention period, we will securely delete or anonymize your personal data using industry-standard methods, including:
- Permanent deletion from active databases and production systems
- Removal from backup systems within standard backup retention cycles (typically 90 days from original deletion)
- Anonymization or aggregation for statistical purposes where complete deletion is not required by law
- Secure overwriting or destruction of physical media containing personal data
Exception: We may retain certain data for longer periods if:
- Required or permitted by applicable law or regulation
- Necessary for the establishment, exercise, or defense of legal claims
- Required for compliance with statutory retention obligations (e.g., accounting, tax, or regulatory requirements)
- You have provided explicit consent for extended retention for specific purposes
7. Your Rights Under Hong Kong PDPO
As a data subject under the Personal Data (Privacy) Ordinance (Cap. 486) of Hong Kong, you have the following rights with respect to your personal data:
Right to Access (Section 18)
You have the right to request access to the personal data we hold about you, including information about how we use and disclose your data, the categories of data held, and to whom it has been disclosed.
Right to Correction (Section 22)
You have the right to request correction of inaccurate, incomplete, misleading, or out-of-date personal data. We will respond to correction requests within the statutory timeframe.
Right to Withdraw Consent
Where we process your personal data based on your consent (e.g., direct marketing, optional cookies), you have the right to withdraw your consent at any time without adverse consequences.
Right to Request Deletion
You may request deletion of your personal data when it is no longer necessary for the purposes for which it was collected, when you withdraw consent (where applicable), or when retention is no longer legally required.
Right to Object to Direct Marketing (Section 35G)
You have the absolute right to opt-out of receiving direct marketing communications at any time, free of charge and without providing reasons. We must comply with your request without delay.
7.1 How to Exercise Your Rights
To exercise any of the above rights, please contact us at:
- Email: info@ckychina.com or dpo@ckychina.com
- Subject Line: "Data Subject Rights Request - [Type of Request]" (e.g., "Data Subject Rights Request - Access Request")
Please include the following information in your request:
- Your full name and contact information (email address and/or phone number)
- Clear description of your request (access, correction, deletion, withdrawal of consent, etc.)
- Any relevant details to help us locate your data (e.g., email address used for inquiry, approximate date of contact, subject of inquiry)
- A copy of your identity document (e.g., ID card or passport) for verification purposes only - we will use this solely to confirm your identity and will securely delete it after verification
7.2 Response Timeline and Fees
Response Timeline:
- We will acknowledge receipt of your request within 10 business days of receiving it
- We will respond substantively to your request within 40 calendar days of receiving your request, in accordance with PDPO Section 19(1)
- If we require additional time due to the complexity of your request or high volume of requests, we will notify you within 40 days and provide a reasonable timeframe for completion (not exceeding an additional 30 days)
- If we are unable to comply with your request, we will provide you with written reasons for our refusal
Data Access Request Fees:
- For data access requests, we may charge a reasonable fee to cover administrative costs in accordance with PDPO Section 28
- The fee will not exceed HKD 200 (or as prescribed by the Personal Data (Privacy) Ordinance and related regulations)
- We will inform you of any applicable fees before processing your request and provide a breakdown of the calculation
- No fees will be charged for correction requests, deletion requests, withdrawal of consent, or objection to direct marketing
- We may waive fees at our discretion, particularly for simple requests
7.3 Right to Complain
If you believe your data protection rights have been violated or if you are dissatisfied with our handling of your personal data or response to your request, you have the right to lodge a complaint with:
Office of the Privacy Commissioner for Personal Data (PCPD)
Address: 12/F, Sunlight Tower, 248 Queen's Road East, Wan Chai, Hong Kong
Complaint Hotline: +852 2827 2827
Fax: +852 2877 7026
Email: enquiry@pcpd.org.hk
Website: www.pcpd.org.hk
The PCPD provides a complaint lodging service free of charge. You may lodge a complaint online, by phone, by mail, or in person.
8. Third-Party Links and External Websites
Our website may contain links to third-party websites, services, or resources that are not operated or controlled by us, including but not limited to:
- Social media platforms (e.g., Facebook, LinkedIn, Instagram, Twitter)
- Partner or affiliate websites
- Supplier or vendor websites
- Industry resources or publications
- Third-party service providers mentioned in our content
Important Disclaimer
We are not responsible for the privacy practices, content, security, or accuracy of third-party websites.
When you click on a third-party link and leave our website:
- This Privacy Policy no longer applies to any data you provide or actions you take on that third-party website
- You will be subject to the privacy policy, terms of service, and data practices of that third-party website
- Any personal data you provide to that website will be governed by their privacy practices, over which we have no control
- We are not liable for any data breaches, privacy violations, or other issues that may arise from your use of third-party websites
- We do not endorse or make any representations about third-party websites or their privacy practices
We strongly encourage you to review the privacy policy of any third-party website you visit before providing any personal information. If you have questions or concerns about how a third-party website handles your data, please contact them directly.
9. Children's Privacy
Our website and services are intended for business-to-business (B2B) communications and are not directed to individuals under the age of 18. We do not knowingly collect personal data from children under 18 years of age.
If you are a parent or legal guardian and believe that your child under 18 has provided us with personal data without your consent, please contact us immediately at info@ckychina.com or dpo@ckychina.com. We will take prompt steps to investigate and delete such information from our systems within a reasonable timeframe.
If you are under 18 years of age, please do not use this website or provide any personal information to us. By using this website, you represent and warrant that you are at least 18 years of age.
10. Changes to This Privacy Policy
We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, business operations, or other factors that affect how we process your personal data.
10.1 How We Notify You of Changes
- Minor Changes: For non-material changes (e.g., clarifications, updated contact information, formatting improvements, or minor administrative updates), we will:
- Update the "Last Updated" date at the top of this policy
- Post the updated policy on our website
- Changes will be effective upon posting
- Material Changes: For material changes that significantly affect how we collect, use, disclose, or protect your personal data (such as changes to purposes of use, categories of recipients, retention periods, or cross-border transfers), we will:
- Provide prominent notice on our website homepage at least 30 days before the changes take effect
- Send email notification to users who have provided their email addresses through contact forms (where technically feasible)
- Obtain your explicit consent where required by applicable law (e.g., for new purposes of data use)
- Provide a summary of key changes for easy review
Your Continued Use: Your continued use of our website after any changes to this Privacy Policy have been posted constitutes your acceptance of those changes. If you do not agree with any changes, please discontinue use of our website and contact us to request deletion of your personal data.
We encourage you to review this Privacy Policy periodically (we recommend at least annually or whenever you submit personal data to us) to stay informed about how we protect your personal data and your privacy rights.
Tip: Bookmark this page and check the "Last Updated" date at the top each time you visit to see if there have been any changes since your last review. You can also contact us to request notification of future policy updates.
11. Contact Us and Data Protection Officer
If you have any questions, concerns, comments, or requests regarding this Privacy Policy, our data protection practices, or how we handle your personal data, please do not hesitate to contact us:
Data Controller:
Company Name: Huizhou Kelin Industrial Development Co., Ltd.
Trading As: CKY Audio
Data Protection Officer (DPO):
Response Commitments:
Business Hours: Monday to Friday, 9:00 AM - 6:00 PM (Hong Kong Time, GMT+8, excluding Hong Kong public holidays)
General Inquiry Response Time: We aim to respond to all general inquiries and questions within 3 business days of receipt
Data Subject Rights Requests: For access, correction, deletion, or other data subject rights requests, please refer to Section 7.2 for statutory response timelines (acknowledgment within 10 business days, substantive response within 40 calendar days)
How to Contact Us:
- For general privacy questions: Email info@ckychina.com
- For data subject rights requests: Email dpo@ckychina.com with subject line "Data Subject Rights Request - [Type]"
- For data breach concerns: Email dpo@ckychina.com with subject line "URGENT: Data Breach Report"
- For complaints: Contact our DPO at dpo@ckychina.com or lodge a complaint with the PCPD (see Section 7.3)
Language: This Privacy Policy is available in English and Simplified Chinese (简体中文). Both versions are provided for your convenience. In case of any discrepancy or inconsistency between the English and Chinese versions, the English version shall prevail for interpretation and legal purposes.
12. Governing Law and Jurisdiction
This Privacy Policy, and any disputes arising from or related to the collection, use, disclosure, or protection of your personal data under this policy, shall be governed by and construed in accordance with the laws of the Hong Kong Special Administrative Region of the People's Republic of China, without regard to its conflict of law principles.
Any disputes, claims, or legal proceedings arising out of or relating to this Privacy Policy or our data processing practices shall be subject to the exclusive jurisdiction of the courts of Hong Kong. By using this website and providing your personal data, you irrevocably submit to the jurisdiction of the Hong Kong courts.
Notwithstanding the above, we retain the right to bring legal proceedings in any jurisdiction where you reside or where a breach of this policy occurs.
Acknowledgment and Consent
By using this website, submitting any contact form, or providing any personal data to us, you acknowledge and confirm that:
- You have read, understood, and agree to be bound by this Privacy Policy in its entirety
- You consent to the collection, use, disclosure, and transfer of your personal data as described in this policy
- You understand your rights under the Hong Kong Personal Data (Privacy) Ordinance and how to exercise them
- You understand where your data will be stored (Hong Kong) and the possibility of cross-border transfers as described in Section 1.3
- You are at least 18 years of age or have obtained parental/guardian consent to use this website
- All information you provide is accurate, complete, and current to the best of your knowledge