Privacy Policy

1. Introduction

Emerald Business Solutions Group Limited respects the privacy of every person who contacts the practice, visits this website or works with the desk on a commercial project. This policy sets out in plain language what personal data the firm collects, why it is collected, how it is used and what choices are available to the people concerned. It has been prepared by the developer known as Emerald Business, which maintains this website on behalf of Emerald Business Solutions Group Limited, and it applies to the whole of the site at https://www.builimited.autos together with the estimating work carried out from the desk in Admiralty.

We believe that a person should be able to understand a privacy policy without legal training, and we have written this one with that aim. Where a term has a technical meaning we explain it in ordinary words. Where the practice makes a choice that limits what it collects, we say so. Where the law requires a particular basis for processing, we name that basis. Nothing in this policy removes any right that a person holds under the laws that apply to the practice, and nothing here is intended to mislead a reader about what happens to personal data.

This policy should be read alongside the service terms published on this website. The two documents work together: the terms describe the commercial relationship between the firm and its clients, while this policy describes how personal data is handled along the way. If a reader finds a conflict between this policy and a written agreement signed with the firm, the signed agreement prevails to the extent of the conflict, and the rest of this policy continues to apply.

2. Who We Are

The controller of personal data described in this policy is Emerald Business Solutions Group Limited. The registered and operating address of the firm is Rm 402 4/F Lippo Centre Tower 2, 89 Queensway, Admiralty, Hong Kong - 999077, Hong Kong (HK). The firm can be reached by email at estimates@builimited.autos and by telephone on +17018001092. A named contact for privacy matters can be requested through either channel, and requests are routed to the person who manages records at the desk.

Emerald Business Solutions Group Limited provides commercial estimating services for computer integrated systems and related technical work. The firm is small by design, and the people who handle personal data are the same people who prepare the estimates, which means that questions about a file can usually be answered by the reviewer who read it. The firm does not sell personal data, does not build advertising profiles from it and does not operate a data brokerage of any kind.

3. Scope of This Policy

This policy applies to personal data collected through the website, through email and telephone contact with the desk, through documents supplied in the course of an estimating engagement, and through any other channel that the firm makes available from time to time. It does not apply to services offered by other organisations, even where those organisations are mentioned on this website or where a link points to them.

Some work involves project records that name individuals, such as a site contact, a design lead or a signatory on a contract. Where those records are supplied to the firm by a client, the client remains responsible for the lawful basis on which the records were collected, and the firm handles them only for the purpose of the estimating engagement. The firm will act on the instructions of the client in relation to those records and will not use them for any unrelated purpose.

This policy is written for readers in Hong Kong and in other jurisdictions, and it describes practices that the firm applies as a matter of good management rather than only as a matter of legal minimum. Certain rights described below may depend on the law of the place where a reader lives. Where the law of a reader gives a stronger protection than this policy describes, that stronger protection will be honoured.

4. Personal Data We Collect

The firm collects only the personal data it needs to answer a question, prepare an estimate, perform an engagement or keep a proper record. The categories are limited and can be described as follows.

• Contact details. A name, an email address, a telephone number and, where relevant, a postal address and an organisation name.
• Correspondence. The content of messages sent to the desk, including attachments such as drawings, specifications, schedules and photographs that a client supplies.
• Commercial records. Information about a project, a contract or a transaction that is necessary to prepare an estimate or maintain an account, including names of contacts and signatories that appear in the documents.
• Technical data. Limited information generated by a visit to the website, such as the type of browser used and the approximate region from which a request was made, where the hosting service records it for security and performance.
• Financial details. Information necessary to issue or receive an invoice, held only where an engagement has been agreed and only for as long as the law and the record require.

The firm does not ask for special categories of personal data, such as information about health, and it asks readers not to include such information in a message unless it is genuinely necessary for the matter being discussed. If such information is received, it will be handled with the same care as the rest of the file and will be removed where it is not needed.

5. How We Collect Data

Most personal data reaches the firm in one of four ways. The first is a direct message: a person sends an email to estimates@builimited.autos, calls +17018001092, or completes the form on the contact page. The second is a document: a client supplies a drawing set, a schedule or a contract that names individuals. The third is a meeting or a call: a reviewer speaks with a contact and records the substance in a file. The fourth is automatic: the hosting service that serves this website may record a small amount of technical information for security and performance, as described in the section on cookies and similar tools.

Where the firm receives a document from a client, the firm does not seek additional personal data about the people named in that document beyond what the engagement requires. If a document contains more personal data than the matter needs, the reviewer will note the excess and, where appropriate, ask the client to supply a reduced version. The habit of collecting only what is needed is one of the simplest protections available, and the firm applies it consistently.

6. Why We Use Personal Data

The firm uses personal data for a small number of connected purposes. It uses contact details to answer a question, to arrange an engagement and to keep a client informed about a piece of work. It uses the content of correspondence and documents to measure, price and review the work that a client has asked for. It uses commercial records to prepare invoices, to reconcile a final account and to defend or explain a number if a question arises later. It uses technical data to keep the website available and secure, and to detect abuse.

The firm does not use personal data to make automated decisions that have a legal or similarly significant effect on a person. Estimating decisions are made by people who read the file and sign the sheet, and the firm does not profile individuals for marketing or credit purposes. Where the firm wishes to use personal data for a purpose that is new and unrelated to the purposes described here, it will explain the new purpose and, where the law requires it, obtain consent before the use begins.

7. Legal Basis for Processing

Different purposes rest on different legal grounds. Where a person has asked the firm to answer a question or to prepare an estimate, the processing is necessary to take steps at that person request before entering into a contract, or to perform a contract that has already been agreed. Where the firm keeps records in order to comply with tax, accounting or professional obligations, the processing is necessary for compliance with a legal obligation. Where the firm protects the website and its records against abuse or loss, the processing is necessary for the legitimate interests of the firm in keeping its systems and its clients safe, and those interests are balanced against the rights of the people concerned.

Where the firm relies on consent, as it does for optional marketing communications, a person may withdraw that consent at any time by replying to a message or by writing to the desk. Withdrawal does not affect the lawfulness of any processing that took place before the withdrawal. The firm keeps the legal basis for each purpose under review and will not rely on consent where another basis is more appropriate.

8. Data in Estimating Work

Estimating is a documentary craft. A reviewer reads drawings, schedules and contracts, takes measurements and prices the results, and in the course of that work a file is built that may name designers, contractors, suppliers and signatories. The firm treats that file as confidential to the engagement. Access is limited to the reviewers assigned to the work, and the working papers are kept together so that the record is complete and can be explained to a client without a search through scattered storage.

Where the firm runs a subcontractor quote round, it may share a scope statement with suppliers. The firm removes personal contact details from a scope statement unless the supplier needs them to price the work, and it asks suppliers to use the information only for the purpose of the quote. Where a document contains a signature or an identity document, the firm does not reproduce it in a wider circulation and will redact it where a copy must be sent.

The firm keeps the working papers of an engagement for the period described in the section on retention, because a final account can be questioned years after it closes. During that period, a client may ask for a copy of the file, and the firm will provide it where doing so does not disclose personal data about another person without a lawful basis.

9. Cookies and Similar Tools

This website is built to work without advertising trackers. The site does not set cookies for advertising or profiling, and it does not embed social media pixels that follow a reader to other sites. Where the hosting service sets a strictly necessary cookie for security or for the delivery of a page, that cookie is used only for that purpose and is not read by the firm for any other reason.

If the firm later introduces a tool that sets a non-essential cookie, such as a preference memory or an analytics service, the firm will describe the tool in this section and will offer a way to decline it where the law requires. A reader who wishes to block all cookies can do so through the settings of the browser, although some functions of a website may not work as intended when cookies are blocked. The firm does not treat the mere use of a browser as consent to a non-essential cookie.

10. Sharing With Others

The firm shares personal data only where it is necessary and only with parties who are bound to protect it. The main recipients are the suppliers and service providers that the firm uses to run its business, such as an email provider, a hosting provider and an accountant. Each of these recipients is given only the data needed for its function, and each is expected to keep it confidential and to use it only for the purpose for which it was supplied.

The firm may also share personal data with a client where the client is the party who supplied it, with a professional adviser where advice is required, and with a court, regulator or law enforcement body where the law compels disclosure. The firm does not sell personal data to any third party, does not trade it for services and does not disclose it to a marketing list operator. If the firm is asked to disclose data by a public authority, it will consider the request carefully and will disclose only what the law requires.

11. International Transfers

The firm is based in Hong Kong, and most of its records remain there. Some service providers, such as an email or hosting provider, may store data in another jurisdiction. Where personal data is transferred outside Hong Kong, the firm takes steps to ensure that the data remains protected to a standard comparable to the one described in this policy. Those steps may include a written agreement with the provider, a review of the provider security arrangements and a limitation on the amount of data that is transferred.

A client or a contact who wishes to know whether a particular communication is stored outside Hong Kong may ask the desk, and the firm will answer as precisely as it can. The firm reviews the location of its records from time to time and will update this policy if a significant change occurs.

12. How Long We Keep Data

The firm keeps personal data only for as long as it is needed for the purpose for which it was collected, or for as long as a legal or accounting obligation requires. Correspondence that does not lead to an engagement is generally kept for a short period and then removed, unless it contains something that must be retained, such as a request that the firm not be contacted again. Records connected to an engagement are kept for the period required to support a final account and to meet tax and accounting rules, which may be several years after the work is complete.

When a retention period ends, the firm deletes the data or renders it anonymous so that it can no longer be linked to a person. Where a record must be kept beyond the ordinary period because of a dispute, an audit or a legal requirement, it is held in a restricted file and is used only for that purpose. The firm does not keep personal data indefinitely simply because storage is inexpensive.

13. How We Protect Data

The firm protects personal data with a set of ordinary but effective measures. Access to records is limited to the people who need them for the work, and the working papers of an engagement are kept together in a controlled location. Devices that hold client data are protected by a password or a passcode and are kept up to date with security patches. Email attachments that contain sensitive material are handled with care, and a document that must be sent outside the firm is reviewed before it leaves the desk.

No system is perfectly secure, and the firm does not claim otherwise. If a security incident affects personal data, the firm will investigate promptly, take steps to limit the harm, notify the people affected where the law requires and report to a regulator where a report is required. The firm keeps a short written record of any incident and the steps taken in response, so that the lesson is not lost.

14. Your Rights

Depending on the law that applies to a reader, a person may have the right to be told whether the firm holds personal data about them, to receive a copy of that data, to have inaccurate data corrected, to have data deleted where there is no good reason to keep it, to restrict how data is used, to object to a particular use and to receive data in a portable form. A person may also have the right to withdraw consent where consent is the basis for processing.

To exercise a right, a person should write to estimates@builimited.autos or call +17018001092 and describe what they would like the firm to do. The firm will respond within a reasonable period and will explain any step it cannot take and the reason. The firm may ask for enough information to confirm identity before acting on a request, because it must not disclose personal data to someone who is not entitled to it. A person who is not satisfied with the response may complain to the privacy regulator in the relevant jurisdiction.

15. Marketing Communications

The firm does not run a newsletter and does not send bulk marketing messages. If the firm wishes to tell a client about a service that may be relevant, it will do so in a personal message and will stop if the client asks it to. Contact details are not added to a list for resale or for use by another organisation. A request to stop receiving any communication will be honoured promptly and will be recorded so that the firm does not make the same approach again by mistake.

16. Privacy for Children

The services of the firm are provided to businesses and to professionals, and the website is not directed at children. The firm does not knowingly collect personal data from a child. If the firm becomes aware that it holds personal data about a child without a proper basis, it will delete the data promptly. A parent or guardian who believes that a child has supplied personal data to the firm may contact the desk, and the matter will be handled with care.

17. Links to Other Sites

This website may contain links to other websites, such as the site of a supplier or a professional body. Those websites are operated by other organisations and are governed by their own privacy policies. The firm does not control those websites and is not responsible for their content or for the way they handle personal data. A reader who follows a link should read the privacy policy of the site they reach before supplying any personal data.

18. Changes to This Policy

The firm reviews this policy from time to time and will update it when the way it handles personal data changes or when the law requires. The date at the top of the page shows when the current version took effect. Where a change is significant, the firm will take reasonable steps to bring it to the attention of the people who are likely to be affected. A reader who continues to use the website or to work with the firm after a change takes effect is treated as having read the updated policy.

19. How to Reach Us

Questions about this policy, requests to exercise a right and complaints about the handling of personal data should be sent to Emerald Business Solutions Group Limited at Rm 402 4/F Lippo Centre Tower 2, 89 Queensway, Admiralty, Hong Kong - 999077, Hong Kong (HK). The firm can also be reached by email at estimates@builimited.autos and by telephone on +17018001092. Messages are read during business hours, Monday to Friday from 09:00 to 18:00 Hong Kong time.

The firm is grateful to every person who takes the time to raise a question about privacy. A clear question often reveals a small improvement in the way records are kept, and the firm treats such a question as a contribution rather than an inconvenience.