Privacy

This policy sets forth JE's practice regarding the collection, use, and disclosure of personal data when you use this Website and the choices you have associated with that data (“Privacy Policy”).

We use your data to provide and improve this Website. By using the Website, you agree to the collection and use of information in accordance with this Privacy Policy. Unless otherwise defined herein, terms used in this Privacy Policy have the same meanings as in JE's Terms of Use, accessible from www.johnsonelectric.com.

1. Collection of Data

JE collects several different types of information for various purposes in order to provide and improve the Website for your use.

Types of Data Collected

• Personal Data
  While using the Website, JE may ask you to provide certain personally identifiable information that can be used to contact or identify you ("Personal Data"), which may include, but is not limited to:
  
  • Email address
  • First name and last name
  • Phone number
  • Address, State, Province, ZIP/Postal code, City
  • Cookies and Usage Data
  
  Your Personal Data may be used to contact you with newsletters, marketing or promotional materials and other information that may be of interest to you. You may opt out of receiving any, or all, of these communications by following the unsubscribe link or instructions provided in any email sent to you by JE.


• Account Information
  When you first register with the Sites, you will be asked and prompted to enter certain information, such as your email address (which will be your user ID), password, telephone number, name, and address.


• Use of Cookies
  A "cookie" is a small text file that may be used to collect information about your activity on the Sites. For example, when someone visits a page within the Sites, a cookie is placed on the user's machine (if the user accepts cookies) or is read if the user has visited the Sites previously. Cookies may also be used to track users across the Web. You may set most browsers to notify you if you receive a cookie, or you may choose to block cookies with your browser, but if you do, you may not be able to take advantage of the personalized features enjoyed by other users who visit the Sites. Some of the cookies we use may be flash cookies or Adobe cookies. Depending on your browser, these cookies may not be automatically deleted. Please check your browser to determine where these types of cookies are stored and how they may be deleted.
  
  For more information on cookies, please see our Cookie Policy.


• Usage Information
  Usage Information refers to all information collected from the Sites such as what action has been applied to the Sites such as clicking logs; your registration details or how you may be using the Sites.


• IP Address
  When you use the Sites, we may automatically log your IP address (the unique address which identifies your computer on the internet) which is automatically recognized by our server.

2. Use of Data

Specially JE uses your information for the purpose for which you provided it to us:

• To notify you about changes to this Website
• To allow you to participate in interactive features of this Website when you choose to do so
• To provide customer support
• To gather analysis or valuable information so that we can improve the website
• To monitor the usage of this Website
• To detect, prevent and address technical issues
• To provide you with news, special offers and general information about other goods, services and events which JE offers that are similar to those that you have already purchased or enquired about unless you have opted not to receive such information

Where and as permitted under applicable law, JE may process your contact information for direct marketing purposes (e.g. trade show invitations, newsletters) and to carry out customer satisfactions surveys, in each case also by e-mail. You may object to the processing of your contact data for these purposes at any time by writing to enquiries(a)johnsonelectric.com or by using the opt-out mechanism provided in the respective communication you received.

3. Legal Basis under General Data Protection Regulation (GDPR)

For a citizen or resident of a member country of the European Union (EU) or the European Economic Area (EEA), the legal basis for collecting and using Personal Data described in this Privacy Policy depends on the Personal Data being collected and the specific context in which it is collected as described below:

JE may process your Personal Data because:

• JE needs to perform a contract with you
• You have given us permission to do so
• The processing derives from JE's legitimate interests while your applicable rights are not
• JE has to comply with applicable law

The legal basis for JE processing data about you is that such processing is necessary for the purposes of:

• JE exercising its rights and performing its obligations in connection with any contract we make with you (Article 6 (1) (b) General Data Protection Regulation),
• Compliance with JE’ legal obligations (Article 6 (1) (c) General Data Protection Regulation), and/or
• Legitimate interests pursued by JE (Article 6 (1) (f) General Data Protection Regulation).

Generally the legitimate interest pursued by JE in relation to our use of your personal data is the efficient performance or management of our business relationship with you.

In some cases, we may ask if you consent to the relevant use of your personal data. In such cases, the legal basis for JE processing that data about you may (in addition or instead) be that you have consented (Article 6 (1) (a) General Data Protection Regulation).

4. Retention of Data

JE will retain your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. JE will retain and use your Personal Data to the extent necessary to comply with our legal obligations (for example, if JE is required to retain your Personal Data to comply with applicable laws), resolve disputes, and enforce legal agreements and policies.

JE will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of the Website, or JE is legally obligated to retain such data for longer time periods.

5. Transfer Of Data

Your information, including Personal Data, may be transferred to — and maintained on — computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from your jurisdiction.

If you are located outside Hong Kong and choose to provide your information to JE, please note that JE transfers the information provided by you through the Website, including your Personal Data if any, to Hong Kong Special Administrative Region, PRC (“Hong Kong”) and process it in Hong Kong.

Your use of the Website under the JE Terms of Use followed by your submission of your personal information constitutes your unreserved agreement to this Privacy Policy in general and the transfer of data under this policy in particular.

JE will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and no transfer of your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of your data and other personal information.

6. Disclosure Of Data

Legal Requirements

JE may disclose your Personal Data in good faith belief that such disclosure is necessary to:

• To comply with a legal obligation
• To protect and defend the rights or property of JE
• To prevent or investigate possible wrongdoing in connection with the Website
• To protect the personal safety of users of the Website or the public
• To protect against legal liability

7. Security Of Data

We use reasonable technical and organisational methods to safeguard your information, for example, by password protecting (via usernames and passwords unique to you) certain parts of the Sites and by using SSL encryption and firewalls to protect against unauthorised access, disclosure, alteration or destruction. However, please note that this is not a guarantee that such information may not be accessed, disclosed, altered or destroyed by breach of such firewalls and secure server software.

Whilst we will use all reasonable efforts to safeguard your information, you acknowledge that data transmissions over the internet cannot be guaranteed to be 100% secure and for this reason we cannot guarantee the security or integrity of any Personal Information that is transferred from you or to you via the internet and as such, any information you transfer to JE is done at your own risk.

Where we have given you (or where you have chosen) a password which enables you to access certain parts of our site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

If we learn of a security systems breach we may attempt to notify you electronically so that you can take appropriate protective steps. By using these Sites or providing Personal Information to us you agree that we can communicate with you electronically regarding security, privacy and administrative issues relating to your use of these Sites. We may post a notice on our Sites if a security breach occurs. We may also send an email to you at the email address you have provided to us in these circumstances. Depending on where you live, you may have a legal right to receive notice of a security breach in writing.

8. Rights Under General Data Protection Regulation (GDPR)

If you are a citizen or resident of a member country of the European Union (EU) or the European Economic Area (EEA), you have certain data protection rights. JE aims to take reasonable steps to allow you to correct, amend, delete, or limit the use of your Personal Data.

If you wish to be informed what Personal Data JE holds about you and if you want it to be removed from our systems, please contact us at dataprotection(a)johnsonelectric.com

In certain circumstances, you have the following data protection rights:

• The right to access. You have the right to request information concerning the personal information we hold that relates to you.
• The right of rectification. You have the right to have your information rectified if that information is inaccurate or incomplete.
• The right to object. You have the right to object to your personal information being used for a particular purpose and you can exercise these rights, for example, via an unsubscribe link at the bottom of any email.
• The right of restriction. You have the right to request that JE restricts the processing of your personal information.
• The right to data portability. You have the right to be provided with a copy of the information JE has on you in a structured, machine-readable and commonly used format.
• The right to withdraw consent. You also have the right to withdraw your consent at any time where JE relied on your consent to process your personal information.

Please note that JE may ask you to verify your identity before responding to such requests.

You have the right to complain to a Data Protection Authority about our collection and use of your Personal Data. For more information, please contact your local data protection authority in EU or EEA.

9. Service Providers, Plugins and Tools

JE may employ third party companies and individuals to facilitate the Website, to provide the Website on our behalf, to perform website-related services or to assist us in analyzing how the Website is used ("Service Providers").

These Service Providers have access to your Personal Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.

Social Media
JE may use social media plugins to enable a better user experience with the use of the Website



Analytics
JE may use Service Providers to monitor and analyze the use of the Website.

Browser Plugin
You can prevent these cookies being stored by selecting the appropriate settings in your browser. However, we wish to point out that doing so may mean you will not be able to enjoy the full functionality of this website. You can also prevent the data generated by cookies about your use of the website (incl. your IP address) from being passed to Google, and the processing of these data by Google, by downloading and installing the browser plugin available at the following link: tools.google.com/dlpage/gaoptout.

Advertising
JE may use online marketing tool to display adverts on the Website.



Web Fonts
JE may use online web fonts to display display texts and fonts on the Website.

Newsletter
If you would like to receive our newsletter, we require a valid email address as well as information that allows us to verify that you are the owner of the specified email address and that you agree to receive this newsletter. No additional data is collected or is only collected on a voluntary basis. We only use this data to send the requested information and do not pass it on to third parties.
We will, therefore, process any data you enter onto the contact form only with your consent per Art. 6 (1) (a) DSGVO. You can revoke consent to the storage of your data and email address as well as their use for sending the newsletter at any time, e.g. through the "unsubscribe" link in the newsletter. The data processed before we receive your request may still be legally processed.
The data provided when registering for the newsletter will be used to distribute the newsletter until you cancel your subscription when said data will be deleted. Data we have stored for other purposes (e.g. email addresses for the members area) remain unaffected.

You may revoke your consent at any time by unsubscribing to the newsletter. This can be done by sending an email to this effect to dataprotection(a)johnsonelectric.com. They can also remove themselves from the mailing list using the unsubscribe link in the newsletter.

Cookie Compliance Solution
JE currently use a cookie solution provided by Optanon (https//www.optanon.com).

Recruitment
You can apply for a position within JE anywhere in the world via an online recruitment application system. By means of this recruitment application system, you can create a profile and apply for a specific vacancy. Via the use of this application and submission of related information, you can provide personal data to JE in connection with the recruiting process. JE and our service provider process personal data for recruitment purposes including organizing selection procedures and manage applications. We disclose your Personal Data to the following service provider:



SSL or TLS encryption
This site uses SSL or TLS encryption for security reasons and for the protection of the transmission of confidential content, such as the inquiries you send to us as the site operator. You can recognize an encrypted connection in your browser's address line when it changes from "http://" to "https://" and the lock icon is displayed in your browser's address bar. If SSL or TLS encryption is activated, the data you transfer to us cannot be read by third parties.

10. Links To Other Sites

This Website may contain links to other sites that are not operated by JE. If you click on a third party link, you will be directed to that third party's site. You’re advised to review the privacy policy of each non-JE site you decide to visit.

JE has no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.

11. Changes To This Privacy Policy

JE may update this Privacy Policy from time to time. Such changes will be posted on this page. The effective date of such changes will be notified via email and/or a prominent notice on the Website, with an update the "effective date" at the top of this Privacy Policy.

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

12. Data Privacy Contact

You can reach our data protection officer at dataprotection(a)johnsonelectric.com.

13. Contact by E-mail or Contact Form

When you contact us by e-mail or through a contact form, we will store the data you provide (your e-mail address, possibly your name and telephone number) so we can answer your questions. Insofar as we use our contact form to request entries that are not required for contacting you, we have always marked these as optional. This information serves to substantiate your inquiry and improve the handling of your request. Your message may be linked to various actions taken by you on the JE website. Information collected will be solely used to provide you with support relating to your inquiry and better understand your feedback. A statement of this information is expressly provided on a voluntary basis and with your consent, art. 6 par. 1a GDPR. As far as this concerns information about communication channels (such as your e-mail address or telephone number), you also agree that we may also, where appropriate, contact you via this communication channel to answer your request. You may of course revoke this consent for the future at any time.

We delete the data that arises in this context after saving is no longer required, or limit processing if there are statutory retention requirements.

14. Privacy Policy for Job Applications

[pursuant to Art. 13 GDPR - Duty to inform when collecting personal data from the data subject]

Thank you for your application to SWP.

We attach great importance to the protection of your data and the protection of your privacy. To ensure that you are fully informed about the collection, processing and use of personal data in the context of our application procedures, please read the following information.

• Responsible for the Processing of Personal Data
  The person responsible for the processing of your personal data within the meaning of data protection law is
  
  Johnson Electric Holdings Limited
  6/F, 12 Science Park East Avenue,
  Hong Kong Science Park
  Shatin, NT, Hong Kong
  Phone: +852 2663 6688
  Email: enquiries(a)johnsonelectric.com
  > Representative(s) of the Company: Patrick Shui-Chung Wang and Winnie Wing-Yee Wang
  
  If you have any questions about data protection at JE, you can contact our data protection officer at any time.
  
  
• Data Protection Officer
  You can contact our data protection officer as follows:
  
  Data Protection Officer of Johnson Electric Holdings Limited
  6/F, 12 Science Park East Avenue,
  Hong Kong Science Park
  Shatin, NT, Hong Kong
  Email: dataprotection(a)johnsonelectric.com



• Further Information on the Processing of Your Data When you apply to us, we process the information we receive from you as part of the application process, e.g. by letter of application, CV, references, correspondence, telephone or verbal information. In addition to your contact details, information about your education, your qualifications, your work experience and your skills are of particular relevance to us. We will judge you only by your suitability for the respective position, so that you do not have to send us a photo.
  
  Your data will initially be processed exclusively for the purpose of the application procedure. If your application is successful, it will be used in your personnel file and for the execution and termination of the employment relationship and deleted in accordance with the regulations applicable to personnel files. If we are currently unable to offer you employment, we will continue to process your data for up to six months after the cancellation has been sent in order to defend ourselves against possible legal claims, in particular due to alleged discrimination in the application process. Your data will initially be accessible to our human resources department, but also to the specialist department of the position to which you have applied, the works council, the equal opportunities officer, and, if required, the institute management and the accounting department. Our administrators and contractors have the technically necessary possibility to access data processed by means of IT. These are strictly bound by our instructions and may not process the data for their own purposes. In certain cases, we may be required to disclose your personal data to third parties, for example to our bank if you receive a refund or to the post office if we communicate with you by letter.
  
  The legal basis for data processing in the application procedure and as part of the personnel file are § 26 Paragraph 1 Sentence 1 BDSG [Federal Data Protection Act] and Art. 6 Paragraph 1 Letter b GDPR and, if you have given your consent, for example by sending information not necessary for the application procedure, Art. 6 Paragraph 1 Paragraph 1 Letter a GDPR. The legal basis for data processing after a refusal is Art. 6 para. 1 subpara. 1 letter f GDPR. The legal basis for budgetary and tax law storage is Art. 6 para. 1 para. 1 lit. c GDPR i.V.m. § 147 AO. The legitimate interest in processing on the basis of Art. 6 para. 1 para. 1 letter f GDPR is the defense against legal claims.
  
  As a rule, we do not require any special categories of personal data within the meaning of Art. 9 GDPR for the application process. We ask you not to send us any such information from the outset. If such information is exceptionally relevant to the application process, we will process it together with your other applicant data. This may include, for example, information about a severe disability which you may voluntarily provide us with and which we must then process in order to fulfil our special obligations with regard to severely disabled persons. In these cases, processing serves the exercise of rights or the fulfilment of legal obligations under labor law, social security law and social protection. The legal basis for data processing is then Art. 9 Para. 2 lit. b GDPR, §§ 26 Para. 3 BDSG [Federal Data Protection Act], 164 SGB [Criminal Code] IX. In exceptional cases it may be necessary to obtain information about your health or a disability or information from the Federal Central Register, i.e. about previous convictions, in order to assess your suitability for the intended activity. The legal basis for this is § 26 BDSG [Federal Data Protection Act].
  
  Your data will neither be used by us for automated decision making or profiling nor passed on to third parties. Your data will be processed by us or on our behalf exclusively in Germany.
  
  
• Voluntarily provide your data
  You are not obliged to provide us with personal data. However, we can only assess your suitability for the position in question if we receive information about your education, work experience and skills in particular, and we cannot include you in the application process without your contact details.
  
  
• Your rights
  According to the Basic Data Protection Ordinance you have
  
  • the right to information free of charge,
  • the right to rectification, deletion or limitation of processing,
  • the right to object to the processing,
  • a right to data transferability.
  If the processing is based on consent, you have the right to revoke your consent at any time without prejudice to the legality of the processing carried out on the basis of the consent until revocation or the processing on another legal basis.
  
  As far as a processing of your personal data is based on art. 6 para. 1 para. 1 lit. e or f GDPR, you have the right to object to the processing according to art. 21 GDPR. If your objection is made for reasons arising from your particular situation, we will no longer process your personal data unless we can prove compelling reasons worthy of protection for the processing, which outweigh your interests, rights and the processing serves to assert, exercise or defend legal claims. If your objection is directed against direct advertising, including profiling, insofar as it is connected with such direct advertising, we will no longer process your personal data for these purposes; however, we do not process applicant data for advertising purposes anyway.
  
  Please contact us with your request using the above contact details and also have the right to complain us at dataprotection(a)johnsonelectric.com. If you have any questions or requests regarding data protection, please do not hesitate to contact us.