PRIVACY POLICY FOR CLIENT
The objective of this Privacy Policy for Client (the “Policy”) is to protect the rights and privacyof individuals’ Personal Data (defined below), by ensuring that the Personal Data will be usedwithin the scope required in view of the nature and scale of the business of Sagawa Express (H.K.)
Co., Ltd. (the “Company”), and in compliance with the The Personal Data (Privacy) Ordinance(Cap.486) and where appropriate other applicable laws and regulations in Hong Kong(collectively,
the “Applicable Law”).
This Policy shall be effective as of August 1st, 2023 and is subject to further changes or revisions(which shall be notified to you). The Company shall continue to review the effectiveness of thisNotice from time to time as and when necessary.
This Policy applies when the Company acts as the data controller of the Personal Data only. For
any activities where the Company is the data processor for other data controller, you may checkthe details of such processing activities from the privacy policy or notice of processing of suchcompany, organization, or service provider who is the data controller of such activity directly.
1.

DEFINITION OF PERSONAL DATA
“Personal Data” refers to any data about an individual which can be used to identify suchindividual, whether from that data alone or in combination with other information. Thisincludes any expression of opinion about an individual and intentions towards an individual.
This also includes personal data held visually, such as photographs and video clips(including CCTV) as well as audio recordings.

2.

PURPOSES FOR COLLECTION, USE & DISCLOSURE OF PERSONAL DATA

2.1.

Collection of Personal Data
The Company may, directly or indirectly, collect your personal data from the followingsources:(1) Information that you or your representative directly provided to the Company;(2) Information that customer and service user directly provided to the Company such as
information of contact person, consignor, and consignee;(3) Personal data received from affiliates and logistic network of the Company;(4) Information received from any agency or organization which is a customer or vendor of
the Company that you work with (as a director, representative, or contact person);(5) Application, website, social media, and/or other public relation media you use in order
to contact the Company;(6) Personal data received from vendor or business partner of the Company such as broker,
delivery service provider, online platform service provider, or logistic agent; or(7) Any reliable public sources.

2.2.

Types of Personal Data Collected
The Company shall only collect personal data that are necessary and adequate (but notexcessive) for a lawful purpose directly related to a function or activity. Depending on
purposes of use and requirement of the operatives in processing personal data, theCompany may collect various types of your personal data including:(1) Identification information such as name-surname, name prefix, date of birth, nationality,1

identification number, taxpayer identification number, fax number telephone number, email, social media account (such as Line ID), address, copy of identification card, copyof driver license, copy of car registration, copy of household registration, copy ofpassport, photo, voice, signature, picture, and video;(2) Personal characteristics such as a copy of the professional license, copy of license (i.e.,international transportation license), and job position;(3) Financial information such as bank account, transaction information, financial credit
information, withholding tax information, payment method, and other payment details;
and(4) Other information such as vehicle registration number, personal data that you provide
to the Company when contacting us such as interest and type of service, communication
with the Company through social media and other channels.
2.3.

Purposes of use and disclosure
The Company will process your personal data to: (i) perform contractual obligations as aparty to the contract, (ii) comply with legal obligations, or (iii) for the legitimate interest.
Personal Data which we collected from you may be collected, used and/or disclosed for thefollowing purposes (collectively, the “Purposes”):(1) Purposes of Providing Delivery and Logistics Related Services(i) Management of goods delivery and logistics including transportation planning,packing of goods for delivery, delivery of goods, coordination with those involved in
the transportation of goods as well as taking any operation to fulfill the purposes asrequested by the customer; and(ii) Tracking and reporting on the status of transportation.
(2) Purpose of Providing Export and Import Related Services(i) Representing customer in export and import of goods including freight planning,arranging and coordinating with a business partner of the Company regarding theexportation and importation as well as taking any operation to fulfill the purposes asrequested by the customer; and(ii) Carrying out any process in relation to the customs clearance including coordinatingwith any relevant governmental organizations, preparing documents forconsideration of relevant governmental organizations, and requesting related
permissions from governmental organizations for importing, exporting, or transiting
goods.
(3) Purposes of Managing Warehouse(i) Management of warehouse and storage services;(ii) Preparing the record for inspection of relevant authorities; and(iii) Supporting legal compliance, and regulations of relevant officials.
(4) Marketing Purpose
The Company will inform and obtain your written consent before processing yourpersonal data in direct marketing activities. Subject to your consent, the Company may
collect, use, and disclose your personal data including but not limited to the following
marketing purposes:(i) Offering information and newsletter in relation to the logistic services of theCompany. In the case where you no longer wish to be contacted for the marketingof services, you may proceed with the opt-out through the channels designated bythe Company;(ii) Service assessment in order to improve the quality of service, and to offer services

2

that you may be interested in;(iii) Setting pattern and improving general marketing activities of the Company; and(iv) Using the information in preparation of advertisement and public relations materials
via any media channels.
The Company will notify you when your personal data are used for direct marking
purpose for the first time. The Company will cease to use your data for such purpose if
so required by you.
(5) Other Purpose(i) Registering customer accounts and creating a database for the provision of logistic
services of the Company;(ii) Procedure for demanding the payment of debt;(iii) Fulfilling our contractual obligations whether directly or indirectly;(iv) Legitimate interests in relation to the carrying out of the business of the Company,
by concerning the fundamental rights of the data subject such as for developing,
improving, predicting, and solving problems that may incur in relation to the provisionof service of the Company;(v) Supporting the stability and security of the Company;(vi) Assessment and management of your requests;(vii)Inspection, analysis, and preparation of documents upon request of governmentalorganizations and regulatory bodies;(viii) Compliance with applicable laws including performing obligations as business
operator of the warehouse, silo, and cold room; andIn the case where the Company appoints third party service provider(s) to process yourPersonal Data (whether within or outside Hong Kong), the Company shall adopt contractualor other means to prevent any Personal Data transferred to the third party service provider(s)from being kept longer than is necessary for processing of the data.
The Company will not disclose or permit the disclosure or make available your Personal Data
other than in accordance with the Purposes unless you have given a prior written consent tothe Company or the Applicable Law allows the Company to do so without obtaining yourconsent.
If you could not share Personal Data that are necessary for the Company to process
Personal Data based on the ground of contractual obligations, or legal obligations, theCompany will not be able to perform its contractual obligations with such subject matter nor
able to comply with legal obligations.
The Company will process Personal Data in strict compliance with Applicable Law. In casewhere you have given a consent to any data processing activity, you may withdraw yourconsent at any time by giving a written notice to the Company.
2.4.

Data Sharing and Disclosure(1) The Company will not disclose your Personal Data without your consent. This is unlessthe disclosure has appropriate legal basis, such as:(i) Is required based on the applicable laws and/or regulations;(ii) Is necessary to respond to an emergency that threatens the life, your health or safety
or another individual which cannot be obtained in a timely way, provided that theCompany shall, in a reasonably timely manner, notify you of the disclosure and thepurposes of the disclosure;(iii) Is necessary for any investigation or proceedings; and(iv) Is necessary to verify your personal particulars and process payment requests in3

relation to the provision of the services which you may be entitled to or may haverequested for.
(2) In order to conduct our business operations more smoothly, we may also be disclosing
the Personal Data you have provided to us to our third party service providers, agents,
and/or our affiliates or related corporations, whether within or outside Hong Kong, or torelevant government authorities or law enforcement agencies when there is legal
obligation or legitimate interest to do so, for one or more of the above-stated Purposes.
This is because such third-party service providers, agents and/or affiliates or related
corporations, or relevant government authorities or law enforcement agencies would beprocessing your Personal Data on our behalf for one or more of the above-statedPurposes. We will rely on the same basis as notified or consented by you for thesetransfer and processing activities. In such cases, we will ensure a standard of protection
for the Personal Data so transferred that is comparable to the protection under theApplicable Law and the Company’s standards.
(3) In all other instances of disclosure of Personal data to third parties with appropriate legal
basis, including express consent from you, insofar as is reasonably practicable theCompany will endeavor to provide adequate supervision over the handling andadministration of Personal Data by such third parties, as well as to provide for adequate
forms of protection over such Personal Data.
3.

RIGHTS OF DATA SUBJECT

3.1.

In accordance with the Applicable Law, you, as a data subject has the following rights (which
may be amended pursuant to any regulations of the data protection law) which are
exercisable in compliance with the Applicable Law:
(1)
(2)
(3)
(4)
(5)
(6)
(7)

The right to withdraw consent you have given to us;
The right to access Personal Data;
The right to rectify Personal Data;
The right to erase Personal Data;
The right to restrict data processing;
The right to Personal Data portability; andThe right to reject the processing of Personal Data.

3.2.

In responding to your request under this clause, the Company may be able to consider only
your Personal Data that the Company processed as a data controller. For the exercising ofyour right for the Personal Data the Company processed as a data processor of other datacontroller, the Company will inform such data controller to consider and proceed according
to your request as your data controller.

4.

DATA PROTECTION OFFICER

4.1. In case of any concerns regarding this Notice or any other issues related to Personal
Data handling, please contact below:
The Company:
Name: Sagawa Express (H.K.) Co., Ltd.
Address: Units 801-803, 8/F., Tins Enterprises Centre, 777 Lai Chi Kok Road
Kowloon, Hong Kong SAR, China
Tel:+852-2489-0282
Email:
shk-information@sgh-global.com

4orData Protection Officer:
Position: Corporate Finance & Administration Division, Division Manager
Address: Units 801-803, 8/F., Tins Enterprises Centre, 777 Lai Chi Kok Road
Kowloon, Hong Kong SAR, China
Tel:+852-2409-9128
Email: shk-hr@sgh-global.com
4.2. When making any complaint or claim, please provide your contact details to enable theCompany to revert to you as soon as practicable.
4.3. The Company does not charge any administrative fees relating to your personal data.
However, a fee in processing certain requests (other than the request for rectification) under
the data protection law may apply.
5.

RETENTION OF PERSONAL DATA

5.1.

The Company has a duty to retain your Personal Data for a period of time after we cease
the relationship with you. Apart from legal purposes, there are other purposes such as
to provide references, or for financial reasons.
Your Personal Data will be retained for period(s) as are reasonable and necessary to meet
the Company’s legal and/or business purposes, and the Company will cease to retain yourPersonal Data as soon as it is reasonably practicable to assume that the purpose forcollection of such Personal Data is no longer being served by such retention, and suchretention is no longer necessary for legal and/or business purposes. Our current practice isto retain certain Personal Data of you for up to seven (7) years, subject to the applicable
anonymization procedures and at all times in accordance with our document retention anderasure practice, and the Applicable Law.

5.2.

5