Privacy Policy

1. Background

This privacy policy lets you know what happens to any personal data that you give to us, or any that we may collect from or about you. It applies to all services and to all cases where we collect your personal data.

This privacy policy applies to personal information processed by or on behalf of Transworld Relocation Limited and its subsidiary or associated undertakings.

A full list of companies can be found on our Contact Us page.

Changes to this privacy policy

We may change this privacy policy from time to time by updating this page in order to reflect changes in the law and/or our privacy practices.

About Transworld Relocation Limited

Transworld Relocation Limited, Flat 1205 Cheung Wei Industrial Building, Chai Wan, Hong Kong Island, Hong Kong

We are a data controller of your personal data.

We have a dedicated GDPR Representative who carries the job title of Chief Privacy Officer (“CPO”). You can contact the CPO using the details at the end of this policy or by writing to the above address, marking it for the attention of the CPO.

2. What kinds of personal information about you do we process?

Personal information that we may process in connection with our services, if relevant, includes:

  • Personal and contact details, such as title, full name, contact details, contact details history, address
  • Your date of birth, gender and/or age
  • Your nationality and passport or visa details
  • Contact details of friends / nominees / other persons – if provided to us to assist with collection, clearance, delivery or any other shipment process
  • Records of your contact with us such as via our business centre telephone number or your IP address or MAC address
  • Services we have performed for you, as well as services you have been interested in by way of detailed quotations
  • The associated payment methods you used to settle our invoices
  • Bank details – only in the rare circumstances where a refund is to be paid to your bank
  • Marketing to you and analyzing data, including history of those communications, whether you open them or click on links, and information about services we think you may be interested in, and analyzing data to help target offers to you that we think are of interest or relevance to you.
  • Information about your property, such as location, number of rooms and property type
  • Photographs of your shipment/items – for security and identification purposes
  • Your residency and/or citizenship status, if relevant, such as your length of residency in a particular country
  • Insights about you and our customers gained from analysis or profiling of customers

3. What is the source of your personal information?

We will collect personal information from the following general sources:

  • From you directly, and any information from family members, associates or beneficiaries of services
  • Information generated about you when you use our services, such as when you make payment by a credit or debit card
  • Information gathered from what you do on our websites. This can show us, for example, which services and routes you are investigating

4. What do we use your personal data for?

We use your personal data, including any of the personal data listed in section 2 above, for the following purposes:

  • Updating your records, tracing your whereabouts and recovering debt
  • Managing any aspect of the service, including, where necessary sharing information with legitimate business partners (for example, overseas customs clearing agents or shipping agents) or regulatory bodies
  • To perform and/or test the performance of, our services and internal processes
  • To improve the operation of our business and that of our business partners
  • To follow guidance and best practice under the change to rules of governmental and regulatory bodies
  • For management and auditing of our business operations including accounting
  • To monitor and to keep records of our communications with you and our staff
  • For market research and analysis and developing statistics
  • For direct marketing communications and related profiling to help us to offer you relevant services. We will send marketing to you by SMS, email, phone, post, and social media
  • To provide personalized content and services to you
  • To develop new services and to review and improve current services
  • To comply with legal and regulatory obligations, requirements and guidance
  • To provide insight and analysis of our customers for ourselves either as part of providing services, helping us improve services, or to assess or improve the operating of our businesses

5. What are the legal grounds for our processing of your personal information (including when we share it with others)?

We rely on the following legal bases to use your personal data:

a) Where it is needed to contractually provide you with our services, such as:

  • Updating your records, tracing your whereabouts to contact you about the status of your shipment and/or account and doing this for recovering debt (where appropriate)
  • Sharing your personal information with business partners and service providers
  • All stages and activities relevant to managing the service – including enquiry, quotation, management of accounts and payments

b) Where it is in our legitimate interests to do so, such as:

  • Managing your services, as detailed in 5 (a) above
  • To perform and/or test the performance of, our services and internal processes
  • To follow guidance and recommended best practice of government and regulatory bodies
  • For management and audit of our business operations including accounting
  • To carry out monitoring and to keep records of our communications with you and our staff
  • For market research and analysis and developing statistics
  • For direct marketing communications and related profiling to help us to offer you relevant services
  • Where we need to share your personal information with people or organizations in order to run our business or comply with any legal and/or regulatory obligations

c) To comply with our legal obligations

d) With your consent or explicit consent:

  • For some direct marketing communications

6. When do we share your personal information with other organizations?

We may share information with the following parties for the purposes listed above:

  • Other Transworld Relocation companies
  • Business partners (for example, couriers, shipping agents or overseas customs clearing agents), or others who are a part of providing your services or operating our business
  • Governmental and regulatory bodies such as Revenue and Customs, or the Financial Conduct Authority
  • Other organizations and businesses who provide services to us such email server hosting providers, IT software and maintenance providers and document storage providers
  • Market research organizations who help us to develop and improve our services

We shall take practical steps to ensure that their employees, officers, agents, consultants, contractors and such other third parties mentioned above who are involved in the collection, use and disclosure of your personal data will observe and adhere to the terms of this privacy policy.

7. Is your personal information transferred outside Hong Kong?

Our Head office is based in Hong Kong but we have a global presence and your personal information will be transferred outside Hong Kong, as our Business Centres are located in several territories.

If shipping internationally, it will also be necessary to transfer your information to our business partners.

We will ensure that suitable safeguards are in place, for example by using approved contractual agreements.

8. How and when can you withdraw your consent?

Where we are relying upon your consent to process personal data, you can withdraw this at any time by contacting us using the details at the end of this policy.

9. What are marketing preferences?

We may use your email address, home address, phone numbers, and social media or digital channels (for example, Facebook or Google) to contact you according to your marketing preferences.

You can stop our marketing at any time by contacting us using the details at the end of this policy or by following the instructions in the communication.

10. Do we do any monitoring involving processing of your personal information?

In this section monitoring means any: listening to, recording of, viewing of, intercepting of, or taking and keeping records of calls, email, text messages, social media messages, in person meetings and other communications.

We may monitor where permitted by law and we will do this where the law requires it, or to comply with regulatory rules, to prevent or detect crime, in the interests of protecting the security of our communications systems and procedures and for quality control and staff training purposes. This information may be shared for the purposes described above.

11. Do you have to provide your personal information to us?

We are unable to provide you with our services if you do not provide certain information to us.

We make every effort to ensure we request only the minimum personal information necessary to properly discharge our contractual obligations.

12. What should you do if your personal information changes?

You should tell us at the earliest opportunity so that we may update our records – either telephone one of our Business Centres or alternatively, log on to your secure account via our website and make the changes yourself.

13. For how long is your personal information retained by us?

Unless we explain otherwise to you, we will hold your personal information based on the following criteria:

  • For as long as we have reasonable business needs, such as managing our relationship with you or for as long as we provide services to you and then for as long as someone could bring a claim against us
  • Retention periods in line with legal and regulatory requirements or guidance, such as audit or inspection by Revenue and Customs in the appropriate territory

14. What are your rights under data protection laws?

All individuals have the following rights under data protection laws. These rights do not apply in all circumstances.

  • The right to be informed about the processing of your personal information
  • The right to request access to your personal information and to obtain information about how we process it
  • The right to have your personal information corrected (“rectified”) if it is inaccurate and to have incomplete personal information completed
  • The right to have your personal information erased (the “right to be forgotten”)
  • The right to restrict processing of your personal information
  • The right to move, copy or transfer your personal information (“data portability”)
  • The right to object to processing of your personal information
  • Rights to question automated decision making which significantly affects you.

If you have a particular question regarding your rights under data protection laws, you can contact us using the details below.

You have the right to complain to the Office of Privacy Commissioner for Personal Data, Hong Kong which enforces data protection laws: