Confidentiality
Leo Paper Group is fully committed to respecting and protecting your privacy in accordance with the requirements of the General Data Protection Regulation (GDPR) and other applicable laws and regulations. This policy is set up to protect the personal data of our customers, suppliers and business partners and subsidiaries.

1. Collection of Personal Data
Leo Paper Group collects personal data provided by you, such as through your business cards, services, request email notifications and/or newsletters, enquiries, transactions or orders. This personal data may include:

• Identification and contact data such as name, job title, phone number, email address, work address, etc.;
• Your feedback or opinions to products and services

2. Purpose of Using Personal Data
Leo Paper Group will use your personal data for the following purposes:

• To communicate with you regarding our products and services
• To respond to your enquires or complaints
• To establish and fulfil orders with you
• To personalize our products and services for you
• To comply with applicable laws and regulations
• To protect Leo Paper’s legitimate business interests and legal rights subject to our obligations under the GDPR

3. Sharing of Personal Data
Leo Paper Group shall treat your personal data as strictly confidential and shall not publish or disclose or share your personal information collected except where we obtain your approval in advance, or to the following parties for the following specific purposes:

• Our subsidiaries in Leo Paper Group, where it is necessary for the provision of services, account administration, sales, marketing and support.
• Leo Paper Group’s headquarters in Hong Kong for fulfilling business operations and product and service provisions. Any transmission of personal data from Leo Paper Group’s subsidiaries in Europe to Leo Paper Group’s headquarters in Hong Kong shall be made in accordance with the European Commission model standard contract clauses relating to data transfers from the European Economic Area.
• Third party contractors which provide us services such as delivering products, distributing corporate information, analyzing data, and processing payment. These parties only have access to such information as necessary to perform their functions and may not use it for any purpose other than to provide services to us
• Our auditors and external legal and financial advisors for obtaining advice
• Marketing and communications agencies which you have agreed may process your personal data in line with our Privacy Policy
• Other third parties in order to satisfy any laws, regulations, or governmental or legal request for such information, or to protect the legitimate interest of Leo Paper Group.

 
4. Retention of Personal Data
Leo Paper Group will retain your personal data for no longer than reasonably necessary in order to fulfil the original purpose for which it has been collected, or to fulfill regulatory requirements, or to enforce our agreements or resolve any dispute.

5. Protection of Personal Data
Leo Paper Group shall comply with its obligations under the GDPR by keeping personal data up to date; by storing and destroying it securely; by not collecting or retaining excessive amounts of data; by protecting personal data from loss, misuse, transfer or publication, unauthorized access and disclosure and by ensuring that appropriate technical measures and physical and managerial procedures are in place to protect personal data. Leo Paper Group also warrants that only authorized employees or other related persons are permitted to use your data for specific purposes. Leo Paper Group does not use automated decision making when processing personal data.

6. Your Right to access and Control of Personal Data
Unless subject to an exemption under the GDPR, you have the following rights with respect to your personal data: -

• The right to request a copy of your personal data which Leo Paper Group holds about you;
• The right to request that Leo Paper Group corrects any personal data if it is found to be inaccurate or out of date;
• The right to restrict Leo Paper Group’s processing of your personal data
• The right to object to Leo Paper Group’s processing of your personal data
• The right to withdraw your consent to Leo Paper Group holding your personal data
• The right to request your personal data is erased where it is no longer necessary for us to retain such data;
• The right, where there is a dispute in relation to the accuracy or processing of your personal data, to request a restriction is placed on further processing;
• The right to make a complaint to the supervisory authority.

You may exercise these rights by contacting us in writing or by email.

7. Further processing
If Leo Paper Group wishes to use your personal data for a new purpose, not covered by this Privacy Policy, then we will provide you with a new notice explaining this new use prior to commencing the processing and setting out the relevant purposes and processing conditions. Where and whenever necessary, we will seek your prior consent to the new processing.

8. How to Contact Us
If you have any questions or concerns about your privacy, please contact us in writing to the Data Protection Officers of relevant subsidiaries in Leo Paper Group: 

• Contact in Hong Kong : Frank Leung (FrankLeung@leo.com.hk, Level 9, Telford House, 16 Wang Hoi Road, Kowloon Bay, Kowloon, Hong Kong) 
• Contact in UK : Victoria Bostock (Vicky@leouk.com, The Oast House, 10 Brewery Court Theale, Reading, RG7 5AJ, United Kingdom)
• Contact in Europe : Jocelyne DeBie (Jocelyne@leo-europe.com, Korte Leemstraat 3 2018 Antwerpen, Belgium)