In the following we will refer to :
- “Personal data” is defined as “any information relating to a natural person who is identified or can be identified, directly or indirectly, by reference to an identification number or to one or more elements specific to him or her”, in accordance with the Data Protection Act of 6 January 1978.
- “Site” means the site www.highgy.com and all its contents.
- “Publisher” or “We”: Fabien Leclerc legal or physical person responsible for the publication and content of the Site.
- “User” or “You”: the Internet user visiting and using the Site.
The present charter aims to inform you of the commitments of the Site with regard to the respect of your private life and the protection of your Personal Data, collected and processed during your use of the Site.
By registering on the Site, you agree to provide us with true information about yourself. Providing false information is contrary to the terms and conditions on the Site.
You will also find a description of your privacy rights and how the law protects you.
Article 2 – Data collected on the Site
The Data collected and subsequently processed by the Site are those that you voluntarily transmit to us by filling in the various forms on the Site. For certain operations on the contents, you may be led to transmit Data concerning you to third party partners through their own Sites, more specifically during payments that you may make. We will not have access to this data, as its collection and processing is governed by the terms and conditions of these parties. We invite you to consult their conditions before communicating your Data in this context. Your IP address (identification number assigned to your computer on the Internet) is collected automatically. You are informed that the Site may implement an automatic tracking process (Cookie), which you can prevent by modifying the relevant parameters of your Internet browser, as explained in the general conditions of this Site.
In general, you can visit the Site without providing any personal information about yourself. In any case, you are under no obligation to transmit this information. Nevertheless, if you refuse, you may not be able to benefit from certain information or Sites.
We also collect, use and share aggregate data such as statistical or demographic data for any purpose. Aggregate data may be derived from your personal information but is not legally required to be so because it does not directly reveal your identity. For example, we may aggregate your usage data to calculate the percentage of users who access a particular feature of the Site.
In order to provide better content and Sites, the Site www.highgy.com uses the Google Analytics Site.
Google Analytics does not track your browsing habits on third-party sites. The information about you that Google Analytics has access to does not contain any personal data about you. We do not collect so-called “sensitive” data. The contact details of the Users of the Site who have registered on the Site will be saved, in compliance with the provisions of the French Data Protection Act of 6 January 1978. In accordance with the latter, they have the right to access, withdraw, modify or rectify the Data they have provided. To do so, they simply need to make a request to the following e-mail address email@example.com, or by post: Highgy APAC Limited – Flat F, 9th Floor, Century Industrial Building, No. 1 Tsing Yeung Circuit, Tuen Mun, New Territories, Hong Kong.
The collection of Users’ Personal Data by the Editor does not require a declaration to the French authority for the protection of Personal Data (the Commission Nationale de l’Informatique et des Libertés – CNIL).
Article 3 – Identity of the controller
The data controller is the company Fabien Leclerc with its registered office at the following address Highgy APAC Limited – Flat F, 9th Floor, Century Industrial Building, No. 1 Tsing Yeung Circuit, Tuen Mun, New Territories, Hong Kong.
Article 4 – Purpose of the Data collected
The data identified as compulsory on the website forms are necessary to be able to benefit from the corresponding features of the website, and more specifically from the operations on the contents offered on the website.
The Site may collect and process the Data of its Users:
- In order to provide you with the information or Sites to which you have subscribed, including: Commercial offers newsletters.
- In order to be able to contact you about: the sale project.
Article 5 – Recipients and use of the Data collected
The Data collected by us are processed for the purpose of carrying out operations on the contents of the Site.
You may receive electronic mail from our Site, including newsletters that you have accepted. You can ask to no longer receive these emails by contacting us at firstname.lastname@example.org or by clicking on the link provided for this purpose in each email sent to you.
Only HIGHGY APAC is the recipient of your Personal Information. This information is never transmitted to a third party, notwithstanding the subcontractors that HIGHGY APAC uses. Neither HIGHGY APAC nor its subcontractors market the personal data of visitors and users of its Site.
We require all third parties to ensure the security of your personal data and to treat it in accordance with the law. We do not allow our third party Site providers to use your data.
Article 6 – Legal basis for data processing
In accordance with the General Data Protection Regulation (GDPR), HIGHGY APAC only processes personal data in the following situations:
- with your consent ;
- where there is a contractual obligation (a contract between HIGHGY APAC and you);
- to meet a legal obligation (under EU or national legislation).
Article 7 – Data Security
You are informed that your Data may be disclosed pursuant to a law, regulation or decision of a competent regulatory or judicial authority or, if necessary, for the purposes of the Publisher’s rights and interests.
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used, altered, disclosed or accessed without authorization. In addition, access to your personal data is subject to a defined and documented security procedure.
Article 8 – Data retention period
The Data is stored at the Site’s host, whose contact details are given in the Site’s legal notice, and is kept for the period strictly necessary to achieve the purposes mentioned above, which may not exceed 24 months. Beyond this period, they will be kept exclusively for statistical purposes and will not be used in any way whatsoever.
Article 9 – Authorised service providers and transfer to a third country of the European Union
HIGHGY APAC informs you that it has recourse to authorised service providers to facilitate the collection and processing of the data you have communicated to us. These service providers are located exclusively in the European Union.
HIGHGY APAC has previously ensured that its service providers have implemented adequate guarantees and comply with strict conditions regarding confidentiality, use and data protection. These service providers are also subject to the General Data Protection Regulation (GDPR).
Article 10 – Computer rights and freedoms
- The right of access: this is your right to request access to your data in order to receive a copy of the personal data we hold; however, due to the obligation of security and confidentiality in the processing of personal data which is incumbent on HIGHGY APAC, you are informed that your request will be processed subject to you providing proof of your identity, in particular by producing a scan or a photocopy of your valid identity document
- The right of rectification: the right to ask us to rectify personal data about you that is incomplete or inaccurate. Under this right, the law allows you to request the rectification, updating, blocking or deletion of data about you that may be inaccurate, erroneous, incomplete or obsolete.
- The right to erasure, also known as the “right to be forgotten”: in some cases, you can ask us to delete the personal data we have about you (unless there is a compelling legal reason for us to keep it).
- The right to restrict processing: you have the right in certain cases to ask us to suspend the processing of personal data,
- The right to data portability: you have the right to request a copy of your personal data in a common format (e.g. a .csv file).
- The right to object: you have the right to object to the processing of your personal data (for example, by prohibiting us from processing your data for direct marketing purposes).
However, the exercise of this right is only possible in one of the following two situations: when the exercise of this right is based on legitimate grounds or when the exercise of this right aims at preventing the use of the data collected for commercial prospecting purposes.
Contact us if you wish to exercise any of the rights described above by writing to us at Highgy APAC Limited – Flat F, 9th Floor, Century Industrial Building, No. 1 Tsing Yeung Circuit, Tuen Mun, New Territories, Hong Kong or by email email@example.com.
You will not be charged for access to your personal data (or for exercising any other rights). However, we may charge you a reasonable fee if your request is manifestly unfounded, repetitive or excessive. In this case, we may also refuse to comply with your request.
HIGHGY APAC shall be entitled, where appropriate, to object to requests that are manifestly abusive because of their systematic or repetitive nature or their number.
We may ask you for specific information to confirm your identity and to ensure your right of access to your personal data (or to exercise any other right). This is a security measure to ensure that personal data is not provided to anyone who is not authorised to receive it. We may also contact you to obtain more information about your request, in order to provide you with a faster response.
We try to respond to all legitimate requests within one month. This one month deadline may be exceeded if your request is particularly complex or if you have made several requests. In this case, we will notify you and keep you informed.
Article 11 – Complaint to the Data Protection Authority
If you consider that HIGHGY APAC is not complying with its obligations with regard to your Personal Information, you may submit a complaint or a request to the competent authority. In France, the competent authority is the CNIL to which you can send a request electronically at the following address: https://www.cnil.fr/fr/plaintes/internet.
a) General information on the cookies present on the site
HIGHGY APAC, as publisher of this Site, may install cookies on the hard disk of your terminal (computer, tablet, mobile phone, etc.) in order to guarantee you smooth and optimal browsing on our Site.
Cookies” are small text files of limited size that allow us to recognize your computer, tablet or mobile phone in order to personalize the Sites we offer.
The information collected through cookies does not in any way allow you to be identified by name. It is used exclusively for our own needs in order to improve the interactivity and performance of our Site and to send you content tailored to your interests. None of this information is communicated to third parties except when HIGHGY APAC has obtained your prior consent or when the disclosure of this information is required by law, by order of a court or any administrative or judicial authority empowered to deal with it.
In order to better inform you about the information that cookies identify, you will find a table listing the different types of cookies likely to be used on the HIGHGY APAC website, their name, their purpose and their retention period at the following address
b) Setting your cookie preferences
You can accept or refuse the deposit of cookies at any time. When you first use the Site www.highgy.com , a banner briefly presenting information about the deposit of cookies and similar technologies appears at the bottom of your screen. This banner warns you that by continuing your navigation on the HIGHGY APAC Site (by loading a new page or by clicking on various elements of the Site for example), you accept the deposit of cookies on your terminal.
Depending on the type of cookie in question, your consent to the deposit and reading of cookies on your terminal may be required.
c) Cookies exempt from consent
In accordance with the recommendations of the Commission Nationale de l’Informatique et des Libertés (CNIL), certain cookies are exempt from prior consent insofar as they are strictly necessary for the operation of the Site or have the sole purpose of enabling or facilitating communication by electronic means. These include session identifier cookies, authentication cookies, load balancing session cookies and cookies for personalising your interface. These cookies are fully subject to this policy insofar as they are issued and managed by HIGHGY APAC.
d) Cookies requiring your prior consent
This requirement concerns cookies issued by third parties and which are qualified as “persistent” in that they remain on your terminal until they are deleted or expire.
As such cookies are issued by third parties, their use and storage are subject to their own privacy policies, a link to which is provided below. This family of cookies includes audience measurement cookies, advertising cookies, which HIGHGY APAC does not use, and social network sharing cookies (Facebook, YouTube, Twitter, LinkedIn, etc.). Social network sharing cookies are issued and managed by the publisher of the social network concerned. Subject to your consent, these cookies allow you to easily share some of the content published on the Site, in particular through a sharing application “button” depending on the social network concerned.
The audience measurement cookies establish statistics concerning the frequentation and use of various elements of the Site (such as the content/pages that you have visited). This data helps to improve the ergonomics of the Site. On the Site www.highgy.com , an audience measurement tool (Google Analytics) is used; its confidentiality policy is available in French at the following Internet address: https://www.google.com/analytics/learn/privacy.html
e) Cookie setting tools
Most Internet browsers are configured by default so that the deposit of cookies is allowed. Your browser offers you the opportunity to modify these standard settings so that all cookies are systematically rejected or that only some of the cookies are accepted or rejected depending on their sender.
CAUTION: We draw your attention to the fact that refusing to deposit cookies on your terminal may nevertheless alter your user experience as well as your access to certain Sites or functionalities of this Site. Where applicable, HIGHGY APAC declines all responsibility for the consequences of the deterioration of your browsing conditions which occur as a result of your choice to refuse, delete or block the cookies necessary for the operation of the Site. These consequences shall not constitute damage and you shall not be entitled to claim any compensation as a result.
Your browser also allows you to delete existing cookies on your terminal or to inform you when new cookies are likely to be placed on your terminal. These settings do not affect your browsing experience, but you will lose all the benefits provided by the cookie.
Please see below for the various tools available to you for setting the parameters of the cookies placed on your terminal.
f) Setting up your internet browser
Each Internet browser has its own cookie management settings. To find out how to change your cookie preferences, please see below for links to the help needed to access your browser’s cookie menu.
Google Chrome: https://support.google.com/chrome/answer/95647?hl=fr
Mozilla Firefox :https://support.mozilla.org/fr/kb/activer-desactiver-cookies
For more information on cookie management tools, you can visit the CNIL website: https://www.cnil.fr/fr/cookies-les-outils-pour-les-maitriser.
g) List of cookies
The detailed list of cookies used on the site www.highgy.com is available at the following address: Coming soon.