Privacy Policy
Last updated: 24/05/2018
Your privacy is extremely important to us so we want you to know exactly
what kind of information we collect about you and how we use it.
We've set out all the details below.
Please take the time to read and understand this policy.
To help you, we've included some links to other websites. It's worth
remembering though that other people, not us, control these websites. We're
not responsible for them.
This notice has different sections which you can click through for further
details of our privacy policy.
About Us
We are
Guangzhou Sunshineblp Furniture Co. Ltd, a wholly owned subsidiary of
BL Packaging Pte Limited.
We are the 'data controller' of the information you provide us with, which
means we control the way information is used and processed.
Direct interactions
You may give us your Identity, Contact, Special Category and Financial Data
by filling in forms or by corresponding with us by post, phone, email or
otherwise. This includes personal data you provide when you:
-
Interact with us at a trade fairs
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speak to or contact our customer services via our website;
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ordering our products or services;
-
request marketing or quotations to be sent to you;
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contact us through our call centre;
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by sending us emails and text messages (SMS or MMS);
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by adding posts, reviews and other comments to any of our websites,
mobile apps or other community forums;
-
by liking or disliking our offers and promotions;
-
by interacting with us on social media platforms such as Facebook or
Twitter etc;
Automated technologies or interactions.
As you interact with our website(s), we will not automatically collect
technical data about your equipment, browsing actions and patterns. We will
not collect this personal data by using cookies, server logs and other
similar technologies. Please see our cookie policy for further details.
Third parties or publicly available sources.
We may receive personal data about you from various third parties as set
out below:
-
Organizers of trade shows we attend.
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CIEF – Canton Fair
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CIFF – Guangzhou / Shanghai Furniture fair
-
IMM – Cologne International Furniture Fair
Your Personal Data
As a business to business company we do not intentionally collect any
personal details of our clients.
As a business to business company, we assume that all data collected at
trade fairs or provided by the organizers of above mentioned trade fairs is
business information and not personal information.
We may collect, store, and use the following categories of business
information about you and your business:
Identity Data
Title, first name, last name, company name,
Contact Data
Billing address, delivery address, email address, telephone number, Skype
address, Wechat / Whatsapp details.
Financial Data
In the event of contact resulting in an order or orders, we will retain
details of your bank account details as part of our order processing
procedures.
Transaction Data
Details about payments to and from you and other details of products and
services you have purchased from us. These include:
-
the time, date and location of purchase;
-
the products that you buy from us;
-
any relevant delivery address;
How we will use information about you?
We will only use your company details in pursuit of business between our
company and yours. It will not be sold or indeed shared with any 3 rd party.
Legitimate Interest
-
means the interest of our business in conducting and managing our
business to enable us to give you the best service/product and the best and
most secure experience;
-
We make sure we consider and balance any potential impact on you (both
positive and negative) and your rights before we process your personal data
for our legitimate interests;
-
We do not use your company data for activities where our interests are
overridden by the impact on you (unless we have your consent or are
otherwise required or permitted to by law).
We may also use your company information in the following situations, which
are likely to be rare:
-
Where we need to protect your interests (or someone else's interests);
- Where it is needed in the public interest or for official purposes.
Purpose/ activity, type of data and lawful basis for processing
We have set out below, in a table format, a description of all the ways we
plan to use your personal data, and which of the legal bases we rely on to
do so. We have also identified what our legitimate interests are where
appropriate.
Note that we may process your personal data for more than one lawful ground
depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we
are relying on to process your personal data where more than one ground has
been set out in the table below.
Some of the above grounds for processing will overlap and there may be
several grounds which justify our use of your personal information.
Purpose/Activity
|
Type of data
|
Lawful basis for processing including basis of
legitimate interest
|
To register you as a new customer
|
(a) Identity
(b) Contact
|
(a) Performance of a contract with you
(b) Your consent
(c) Necessary for our legitimate interest to set up and
manage your account
|
To process and deliver your order including:
(a) Manage payments, fees and charges
(b) Collect and recover money owed to us
|
(a) Identity
(b) Contact
(c) Financial
(d) Transaction
(e) Marketing and Communications
|
(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to fulfil your
order or recover debts due to us)
|
To manage our relationship with you which will include:
(a) Notifying you about changes to our terms or privacy
policy
(b) Responding to your queries and comments, social media
posts and questions.
|
(a) Identity
(b) Contact
(c) Profile
(d) Marketing and Communications
|
(a) Performance of a contract with you
(b) Necessary to comply with a legal obligation
(c) Necessary for our legitimate interests (to keep our
records updated and to study how customers use our
products/services)
(d) Your consent
|
To administer and protect our business and this website
(including troubleshooting, data analysis, testing, system
maintenance, support, reporting and hosting of data)
|
(a) Identity
(b) Contact
(c) Technical
|
(a) Necessary for our legitimate interests (for running our
business, provision of administration and IT services,
network security, to prevent fraud and in the context of a
business reorganisation or group restructuring exercise)
(b) Necessary to comply with a legal obligation
|
To deliver relevant website content and advertisements to
you and measure or understand the effectiveness of the
advertising we serve to you
|
(a) Identity
(b) Contact
(c) Profile
(d) Usage
(e) Marketing and Communications
(f) Technical
|
Necessary for our legitimate interests (to study how
customers use our products/services, to develop them, to
grow our business and to inform our marketing strategy)
|
To make suggestions and recommendations to you about goods
or services that may be of interest to you
|
(a) Identity
(b) Contact
(c) Technical
(d) Usage
(e) Profile
|
Necessary for our legitimate interests (to develop our
products/services and grow our business)
|
Marketing
Promotional offers from us
If you have expressly opted-in to receive marketing from us we may use your
Identity, Contact, Technical, Usage and Profile Data to form a view on what
we think you may want or need, or what may be of interest to you. This is
how we decide which products, services and offers may be relevant for you
(we call this marketing).
You will receive marketing communications from us if you have requested
information from us or purchased goods or services from us or if you
provided us with your details when you entered a competition or registered
for a promotion and, in each case, you have not opted out of receiving that
marketing.
Third-party marketing
We will never offer your details to any 3rd party outside the BL
Packaging group of companies
Opting out
You can ask us or third parties to stop sending you marketing messages at
any time through our website or by contacting us at any time.
Cookies
You can set your browser to refuse all or some browser cookies, or to alert
you when websites set or access cookies. If you disable or refuse cookies,
please note that some parts of this website may become inaccessible or not
function properly. For more information about the cookies we use, please
click here.
Change of purpose
We will only use your business information for the purposes for which we
collected it, unless we reasonably consider that we need to use it for
another reason and that reason is compatible with the original purpose.
If we need to use your business information for an unrelated purpose, we
will notify you and we will explain the legal basis which allows us to do
so.
Please note that we may process your business information without your
knowledge or consent, in compliance with the above rules, where this is
required or permitted by law.
Disclosure of Company Data
On occasion we may have to share your company data with the parties set out
below for the purposes set out.
Internal Third Parties
Companies, brands and businesses within our group
External Third Parties
-
Service providers:
acting as processors based within the EEA who provide IT and system
administration services.
-
Professional advisers:
acting as processors or joint controllers including lawyers, bankers,
auditors and insurers based within the EEA who provide consultancy,
banking, legal, insurance and professional service providers.
-
HM Revenue & Customs, regulators and other authorities:
acting as processors or joint controllers based in the United Kingdom
who require reporting of processing activities in certain
circumstances.
-
Other people who help us provide our websites:
They include information technology experts who design and host our
websites,
-
Our insurers and insurance brokers:
who provide us with comprehensive cover against the risks of running a
business as big as ours. (They may keep this information for the
purpose of ongoing risk assessment and insurance broking and
underwriting services.)
-
Banks and finance companies:
where we have allowed them to offer you the possibility of buying our
products on credit or with a loan arranged through our stores or
online. (They may keep this information for their related banking and
finance purposes)
-
Credit reference agencies:
who supply information on file for future business purposes.
-
With social media companies such as Facebook and Twitter:
and our advertising partners to enable us to run targeted promotions
for you on their platforms;
-
Any new business partners:
we may have over time, for example, in the event of a joint venture,
reorganisation, business merger or sale that affects us.
-
The Police, local authorities, Her Majesty’s Revenue and Customs
(HMRC), the courts and any other government authority:
if they ask us to do so (but only if us doing so is lawful).
-
Other people who make a ‘subject access request':
where we are required to do so by law.
-
We may also share the information we collect where we are legally
obliged to do so, e.g. to comply with a court order.
-
Any social media posts or comments you send to us:
(on the Sunshine BLP Facebook page, for instance) will be shared under
the terms of the relevant social media platform (e.g. Facebook or
Twitter) on which they’re written, and could be made public. Other
people, not us, control these platforms. We’re not responsible for this
kind of sharing. Before you make any remarks or observations about
anything, you should review the terms and conditions and privacy
policies of the social media platforms you use. That way, you’ll
understand how they will use your information, what information
relating to you they will place in the public domain, and how you can
stop them from doing so if you’re unhappy about it. It’s worth
remembering too that any blog, review or other posts or comments you
make about us, our products and services on any of our blogs, reviews
or user community services will be shared with all other members of
that service and the public at large. You should take extra care to
ensure that any comments you make on these services, and on social
media in general are fit to be read by the public, and are not
offensive, insulting or defamatory. Ultimately, you are responsible for
ensuring that any comments you make comply with any relevant policy on
acceptable use of those services.
-
Third parties:
to whom we may choose to sell, transfer, or merge parts of our business
or our assets. Alternatively, we may seek to acquire other businesses
or merge with them. If a change happens to our business, then the new
owners may use your personal data in the same way as set out in this
privacy notice. We require all third parties to respect the security of
your personal data and to treat it in accordance with the law. We do
not allow our third-party service providers to use your personal data
for their own purposes and only permit them to process your personal
data for specified purposes and in accordance with our instructions.
We share your company data within the BL Packaging Pte Ltd Group. This may
involve transferring your data outside the European Economic Area (EEA).
All of our external third parties are based outside the European Economic
Area (EEA) so their processing of your personal data will
involve a transfer of data outside the EEA.
Whenever we transfer your personal data out of the EEA, we ensure a similar
degree of protection is afforded to it by ensuring at least one of the
following safeguards is implemented:
- We will only transfer your company data to countries that have been
deemed to provide an adequate level of protection for personal data by the
European Commission. For further details, see European Commission: Adequacy
of the protection of personal data in non-EU countries.
- Where we use certain service providers, we may use specific contracts
approved by the European Commission which give personal data the same
protection it has in Europe. For further details, see European Commission:
Model contracts for the transfer of personal data to third countries.
- Where we use providers based in the US, we may securely transfer data to
them if they are part of the Privacy Shield which requires them to provide
similar protection to personal data shared between the Europe and the US.
For further details, see European Commission: EU-US Privacy Shield.
Please contact us if you want further information on how we transfer your
personal data out of the EEA.
All information is stored electronically and those systems are
protected by passwords and regular software security updates
How long do we keep your information for?
To make sure we meet our legal data protection and privacy obligations, we
only hold on to your information for as long as we actually need it for the
purposes we acquired it for in the first place.
In most cases, this means we will keep your information for as long as you
continue to shop with us or use our services, and for a period of time
afterwards if you stop doing so just in case you begin shopping with us
again.
After that we will either delete it or anonymise it so that it cannot be
linked back to you.
We will only retain your personal information for as long as necessary to
fulfil the purposes we collected it for, for example for any legal,
accounting, or reporting requirements.
By law we have to keep basic information about our customers (including
Contact, Identity, Financial and Transaction Data) for six years after they
cease being customers for tax purposes.
In some circumstances you can ask us to delete your data: see Request erasure below for further information.
In some circumstances we may anonymise your personal data (so that it can
no longer be associated with you) for research or statistical purposes in
which case we may use this information indefinitely without further notice
to you.
In some circumstances we may anonymise your personal data (so that it can
no longer be associated with you) for research or statistical purposes in
which case we may use this information indefinitely without further notice
to you.
If your query is in connection are with ‘personal information’
Under certain circumstances, by law you have the right to:
-
Request access:
To your personal information (commonly known as a "data subject access
request"). This enables you to receive a copy of the personal
information we hold about you and to check that we are lawfully
processing it.
-
No fee usually required:
You will not have to pay a fee to access your personal data (or to
exercise any of the other rights). However, we may charge a
reasonable fee if your request is unfounded, repetitive or
excessive. Alternatively, we may refuse to comply with your request
in these circumstances.
-
What we may need from you:
We may need to request specific information from you to help us
confirm your identity and ensure your right to access your personal
data (or to exercise any of your other rights). This is a security
measure to ensure that personal data is not disclosed to any person
who has no right to receive it. We may also contact you to ask you
for further information in relation to your request to speed up our
response.
-
Time limit to respond:
We try to respond to all legitimate requests within one month.
Occasionally it may take us longer than a month if your request is
particularly complex or you have made a number of requests. In this
case, we will notify you and keep you updated.
-
Request access:
Of the personal information that we hold about you. This enables you to
have any incomplete or inaccurate information we hold about you
corrected. We may need to verify the accuracy of any new data you
provide to us.
-
Request erasure:
Of your personal information. This enables you to ask us to delete or
remove personal information where there is no good reason for us
continuing to process it. You also have the right to ask us to delete
or remove your personal information where you have exercised your right
to object to processing (see below), where we may have processed your
information unlawfully or where we are required to erase your personal
data to comply with local law. Note, however, that we may not always be
able to comply with your request of erasure for specific legal reasons
which will be notified to you, if applicable, at the time of your
request.
-
Object to processing:
Of your personal information where we are relying on a legitimate
interest (or those of a third party) and there is something about your
particular situation which makes you want to object to processing on
this ground. You also have the right to object where we are processing
your personal information for direct marketing purposes. In some cases,
we may demonstrate that we have compelling legitimate grounds to
process your information which means we can continue to process your
personal information.
-
Request the restriction of processing:
Of your personal information. This enables you to ask us to suspend the
processing of your personal data in the following scenarios:
-
(a) if you want us to establish the data's accuracy;
-
(b) where our use of the data is unlawful but you do not want us to
erase it;
-
(c) where you need us to hold the data even if we no longer require
it as you need it to establish, exercise or defend legal claims; or
-
(d) you have objected to our use of your data but we need to verify
whether we have overriding legitimate grounds to use it.
-
Request the transfer:
Of your personal information to another party. We will provide to you,
or a third party you have chosen, your personal data in a structured,
commonly used, machine-readable format. Note that this right only
applies to automated information which you initially provided consent
for us to use or where we used the information to perform a contract
with you.
-
Right to withdraw consent at any time:
Where we are relying on consent to process your personal data. However,
this will not affect the lawfulness of any processing carried out
before you withdraw your consent. If you withdraw your consent, we may
not be able to provide certain products or services to you. We will
advise you if this is the case at the time you withdraw your consent.
-
PLEASE NOTE - As a company that only collects business information,
any ‘personal data’ will have been given in connection with the
user’s business and will be therefore deemed as business and will
be dealt with as outlined above.
Fees for excessive or unreasonable requests
You will not have to pay a fee to access your personal information (or to
exercise any of the other rights). However, we may charge a reasonable fee
if your request for access is unfounded or excessive. Alternatively, we may
refuse to comply with the request in such circumstances.
What we may need from you
We may need to request specific information from you to help us confirm
your identity and ensure your right to access the information (or to
exercise any of your other rights). This is another appropriate security
measure to ensure that personal information is not disclosed to any person
who has no right to receive it.
The BL Packaging Pte Ltd Data Protection Officer (DPO) oversees compliance
with this privacy notice. If you have any questions or concerns about this
Privacy Notice or how we handle your personal information, please contact
the DPO at This email address is being protected from spambots. You need JavaScript enabled to view it.. You
have the right to make a complaint at any time to the Information
Commissioner's Office (ICO) https://ico.org.uk/, the UK supervisory
authority for data protection issues.