Privacy Policy

Pearlgates Associates Ltd (PGC) is an international telecommunication service provider for class 4 and class 5 voice business. The privacy of all individuals that we come in contact with is very important to us. We are taking a number of measures to ensure that your Personal Data ('Personal Data' or 'Data') is properly and lawfully processed and protected. This Policy applies to all services directly provided by PGC and the websites owned by PGC. All our processing of Personal Data is proper, careful and in accordance with the law, as described in this policy. We make sure that all our processing is done for specified and legitimate purposes and is based on legal grounds. We also take all necessary measures to ensure that our Personal Data is correct, accurate, adequate, complete, relevant and not exces-sive. If we are processing any Personal Data concerning you, you have a right to access and rectify this Personal Data by contacting our legal departmenrt. We encourage you to inform us of any required updates or corrections of your Personal Data. Wherever necessary, we notify the relevant Data Protection Authorities about our specific processing of Personal Data and make sure we follow the instructions and comply with the demands made by these authorities. Employees and contracting third parties who have access to any of PGC Personal Data are required to comply with all procedures and prohibitions pertaining to this policy. This Privacy Policy may be changed at any time, without prior notification. PGC respects the privacy of its customers, suppliers, employees, job applicants and all visitors to our websites who may choose to provide Personal Data. We recognize the importance of adequate protection and management of Personal Data. This Policy will help you understand what types of Personal Data we may collect, how that Personal Data may be used, and with whom the Personal Data may be shared.

What type of Data do we collect?

In order to conduct our daily business as a telecommunications company, as well as to comply with all legal and contractual obligations, we collect Personal Data from a variety of individuals. Among these individuals are employees and applicants, customers, suppliers and third party contacts, visitors to our websites, etc. We only collect Personal Data for clearly specified and legitimate purposes as outlined in this Policy, and we only process the Personal Data in a way that is compatible with the purpose or purposes for which it was collected. If you provide us with your Personal Data, this means you will have voluntarily done so. You always have the right not to provide us with your Personal Data. We will always respect such a refusal, but it might mean that we are unable to perform all services or contracts with you. As a general rule, we will not collect, use, or transfer Sensitive Personal Data except to comply with applicable legislation or to serve your particular interests. If we do process any Sensitive Personal Data about you, for any purpose not mentioned in this Privacy Policy, we will ask for your prior consent. The databases in which your personal data is stored meet the security requirements established pursuant to articles 24 and 25 of the EU Regulation. Access to the databases by both internal and external persons in charge of processing is regulated by our Privacy Organizational Model. Access is enabled depending on the tasks and responsibilities of the persons in charge of processing who liaise with you, and is tracked by our computer system. Both the internal or external collaborators have signed specific letters of appointment, in compliance with the obligations of fairness, lawfulness and transparency imposed by the Regulation and protecting your privacy and rights.

Data Collection devices

In addition to Personal Data, we may use Data collection devices such as "cookies" on certain web pages to help analyze our web page flow and measure promotional effectiveness. Cookies are small files containing a string of characters to identify your browser. Cookies allow the website to remember important Data that will make your visit to the site more useful. You can reset your browser to refuse cookies or warn you when they are being sent. Please note that by turning cookies off, you may not have access to all features available on our website. We also use logging systems on our internal network to register the use of our computer systems. This is done for the purpose of ensuring the performance, integrity and security of these systems. When during the download process you are asked to allow access to your phone's camera and microphone this access is only related to the functionality you use and no data whatsoever, are collected through these resources by us.

Links to websites outside of PGC

Our websites may contain links to other websites. PGC does not control these sites or their privacy practices. This PGC Privacy Policy does not apply to external Web areas. The Personal Data you choose to give to parties outside PGC is not covered by PGC's Privacy Policy. We encourage you to review the Privacy Policy of any company or website before submitting any Personal Data.

Our processing of your Data

We only process your Personal Data for the purposes described in this Privacy Policy. These purposes include: Governmental reporting and fulfilling legal obligations; Our telecommunications operations; Recruitment and staff management; Training and professional development; Finance and administration (including payroll and benefits administration); Customer and supplier business relationship management. All person having access to your data have signed specific letters of appointment, in compliance with the obligations of fairness, lawfulness and transparency imposed by the Regulation and protecting your privacy and rights.

Direct marketing

If we process your Data for a different purpose than the purpose for which it was collected, we will ask for your consent prior to such processing. Your Personal Data may be processed in a hard copy or digital format. We will take all reasonable measures necessary to ensure the security of your Personal Data in accordance with this Privacy Policy.

Processing of employee Personal Data

PGC collects Personal Data from its employees and applicants in connection with administration of its Human Resources and payroll programs and functions. These programs and functions include, but are not limited to: job applications and hiring programs, compensation and benefit programs, performance appraisals, training, access to PGC's facilities and computer networks, employee profiles, internal intranet employee directories, Human Resources recordkeeping, and other employment related purposes. Some of the Personal Data collected for these purposes may be processed by our subsidiaries and shared with our corporate headquarters in Bratislava. It is the policy of PGC to keep all past and present employee Personal Data private from disclosure to third parties. There are some business related exceptions and they are: To comply with applicable legislation or government agency requests; Inquiries from third parties with a signed authorization from the employee to release the Data, except in situations where limited verbal verifications are acceptable; Third parties (processors) with which we have contractual agreements to assist in administration; Other cases mentioned in this Privacy Policy in which we transfer or disclose Personal Data.

Processing of customer, supplier and third party Personal Data

In order to conduct our daily business, we are in contact with a number of other businesses, such as customers, suppliers and third party service providers (e.g. salary administration services, consultants, accountants, etc). We will inevitably come into contact with individuals working for these other businesses and we will have access to some of their Personal Data (e.g. names, phone numbers, e-mail addresses, etc.). The Personal Data of these customers and suppliers and other business contacts will only be processed for the purpose of entering into or the performance of a contract with the customers, suppliers or third party. The customer, supplier and third party Personal Data will be processed and secured in accordance with this Privacy Policy.

Your Right as Data Subject

You can at any time exercise your rights of access (Article 15), rectification (Article 16), erasure respective right to be forgotten (Article 17), restriction of processing (Article 18), and data portability (Article 20) under the EU regulation, by contacting the Data Controller or the Data Processor (e-mail: info@pearlgatescommunication.com).

Transfer and disclosure of Personal Data

We will not transfer or disclose your Personal Data for any other purpose than described in this Privacy Policy. If and when we do transfer or disclose your Personal Data, we will take steps to ensure it is done in accordance with this Privacy Policy and applicable legislation.

Transfer and disclosure of Personal Data within PGC

In order to operate as an international telecommunications company, we may transfer your Personal Data to other companies within PGC for our business purposes. We may also transfer your Personal Data from one office within PGC to another, including transfers to and from our corporate headquarters in Slovakia and transfers to and from our offices in other parts of the world. In compliance with the Directive, we will ask for your consent wherever there is a legal obligation to do so. We will always make best efforts to transfer your Data in accordance with all legal requirements. All legal entities within PGC will take steps to safeguard the processing of your Personal Data in accordance with this Privacy Policy.

Transfer and disclosure of Personal Data to customers, suppliers and third parties

For the purposes described in this Privacy Policy, we may transfer or disclose Personal Data to customers, suppliers or third party service providers. We will minimise the amount of Personal Data that we transfer by providing information that is rendered anonymous where possible. It is our policy to require customers, suppliers and third parties to process the Personal Data they receive from us in a lawful, safe and responsible manner in accordance with this Privacy Policy, taking all appropriate security and confidentiality measures. PGC reserves the right to disclose Personal Data to a third party if there is a legal obligation to do so. PGC also reserves the right to disclose and/or transfer Personal Data to a third party in the event of a proposed or actual purchase, sale, lease, merger, or any other type of acquisition, disposal, or financing of all or any portion of PGC or of any of the business or assets or shares of PGC or any of its subsidiaries.

Security of Personal Data

It is our practice to apply appropriate technical and organizational measures to avoid loss of Personal Data and unlawful accessing or processing. We are constantly making an effort to ensure that these measures ensure an adequate level of security, taking into account: The state of technology; The risks posed by the processing; The nature of the Personal Data, and The cost of implementing these measures. We have a number of measures in place to ensure the security of digitally stored Personal Data, such as a strict policy on access authorization, instructions in our Binding Corporate Rules on how to ensure security of Personal Data, a back-up procedure and secured connections. We also have adequate measures in place to secure Personal Data on hard copy and to physically secure back-up tapes of our digital Data. Access to your Personal Data is restricted to individuals who need such access in order to assist with our telecommunications services. We have strict confidentiality obligations that apply to these individuals. Failure to meet these obligations may result in disciplinary and other actions, including dissolution of a contract, termination of employment and criminal prosecution. The databases in which your personal data is stored meet the security requirements established pursuant to articles 24 and 25 of the EU Regulation. Access to the databases by both internal and external persons in charge of processing is regulated by our Privacy Organizational Model. Access is enabled depending on the tasks and responsibilities of the persons in charge of processing who liaise with you, and is tracked by our computer system.

Retention of Personal Data

We are aware of the importance of rules on the timely destruction of Personal Data. We are making an effort to ensure that your Personal Data is not stored for any longer than necessary for the purpose for which we collected or processed it. This means that it is our practice to destroy your Personal Data as soon as possible after it is no longer necessary for the purpose for which it was collected. In some cases we do store your Data for a longer period of time than would be necessary for the purpose for which it was collected, e.g. when: There is a legal obligation to do so; We store the Data for historical, statistical or scientific purposes; There is an overriding interest of PGC to retain the Data, in which case we will take the necessary steps to comply with all relevant legislation. This may mean that we will notify this storage to one or more Data Protection Authorities (DPA's). It may also occur that we would like to retain some of your Personal Data for specific reasons, e.g. to stay in touch with you over time. In that case, we will regularly contact you to obtain your consent to retain your Data.

Revoking Consent

In accordance with the available choices and as required by current law, you may revoke your previous consent or raise objections to the processing of your data at any time, for legitimate reasons and without charges, by contacting the Data Controller or the Data Processor (e-mail: info@pearlgatescommunication.com), and in the future we will apply the preferences expressed by you.

Consent

As stated in this Privacy Policy, we will on occasion request your consent to process your Personal Data for a particular purpose. We will take measures to ensure that such consent is given unambiguously. Such examples of requesting your consent can include: asking you to reply to an email, tick a box on a website, or sign a form. Please note that, in principle, all forms of consent, whether express or implied, are valid. Such examples can include written (including email) or verbal consent. Even your behaviour may imply your consent to processing your Personal Data for a certain purpose, e.g. providing your business card or contact details. We will always make an effort to ensure that there is no misunderstanding about the processing covered by your consent. If you give your consent, it means you have done so voluntarily. This implies that you always have the right to refuse your consent. We will always respect such a refusal, but it might mean that we are unable to perform all services or all contracts with you. We will inform you of these inabilities, if they occur.

Data Controller

The data controller is Pearlgates Associates Ltd, represented by it's CEO Andreas Stegmaier and you may at any time contact us in writing (hard copy or email) under the following address:


Pearlgates Associates Ltd.
Suite 2405,
Progress Commercial Bldg., 9 Irving Street,
Causeway Bay, 

Hong Kong Island, Hong Kong
info@pearlgatescommunication.com