Privacy policy

Principles

The ten principles that from this policy are interrelated, and Nicewell Group will adhere to the ten principles as a whole. This policy, then, applies to personal information about Nicewell Group’s customers and employees that is collected, used, or disclosed by Nicewell Group. This policy applies to the management of personal information in any form, whether oral, written or electronic. This policy does not, however, impose limits on the collection, use or disclosure by Nicewell Group of any information that is publicly available, including the name, title, business address or telephone number of a customer or employee.

1. Accountability

Nicewell Group is responsible for person information under its control. Nicewell Group’s Privacy Official is accountable for Nicewell Group’s compliance with this policy.

Other individuals within Nicewell Group may be delegated to act on behalf of Nicewell Group’s Privacy Official or to take responsibility for the day-to-day collection and processing of personal information.

Nicewell Group is responsible for personable information in its possession or custody, including information that has been transferred to a third party for processing or other purpose related to Nicewell Group’s business and operation. Nicewell Group will use contractual or other means to provide a comparable level of protection while the information is in the possession of the third party.

l Implementing procedures to protect personal information;

l Establishing procedures to receive and respond to inquiries or complaints;

l Training and communicating to employees and Nicewell Group’s policies and practices

l Developing information to explain Nicewell Group’s policies and practices

2. Identifying Purpose

Nicewell Group will identify the purposes for which personal information is collected at or before the time the information is collected.

Generally, Nicewell Group collects personal information to:

l Establish and maintain responsible commercial relations with customers and employees;

l Provide ongoing service to customers;

l Understand customers’ needs;

l Develop, enhance, market or provide other services;

l Manage and develop its business and operations, including employee and employment matters

l Satisfy legal and regulatory requirements

3. Consent

The knowledge and consent of a customer or employee are required for the collection, use or disclosure of personal information, except where inappropriate.

In certain circumstances, personal information can be collected, used or disclosed without the knowledge and consent of the individual. For example, legal, medical, or security reasons may make it impossible or impractical to seek consent. Nicewell Group may also collect, use and disclose personal information without knowledge or consent if seeking the consent of the individual might defeat the purpose of collecting the information, such as in the investigation of a branch of an agreement or a contravention of a federal or provincial law. Nicewell Group may also collect, use and disclose personal information without knowledge or consent if there is an emergency where the life, health or security of an individual is threatened.

In obtaining consent, Nicewell Group will use reasonable efforts to ensure that a customer or employee is advised of the identified purposes for which personal information will be used or disclosed. Generally, Nicewell Group will seek consent to use and disclose personal information at the same time it collects the information. However, Nicewell Group may seek consent to use and disclose personal information after it has been collected, but before it is used or disclosed for a new purpose. In determining the appropriate form of consent, Nicewell Group will take into account the sensitivity of the personal information and the reasonable expectations of its customers and employees.

Nicewell Group will require customers to consent to the collection, use or disclosure of personal information as a condition of the supply of service only if the collection, use or disclosure is required to fulfill the identified purposes. However, in general, the use of Nicewell Group’s services by a customer or the acceptance of employment or benefits by an employee, constitutes implied consent for Nicewell Group to collect, use and disclose personal information for all identified purposes.

A customer or employee may withdraw consent at any time, subject to legal or contractual restrictions and reasonable notice. Customers and employees may contact Nicewell Group for more information regarding the implications of withdrawing consent.

4. Limiting Collection

Nicewell Group will limit the collection of personal information to that which is necessary for the purposes identified by Nicewell Group. Nicewell Group will collect personal information by fair and lawful means.

Nicewell Group collects personal information primarily from its customers or employees. Nicewell Group may also collect personal information from other sources with the employee’s or potential employee’s consent, including credit bureaus, employers or personal reference or other third parties that represent that they have the right to disclose the information.

5. Limiting Use, Disclosure and Retention

Nicewell Group will not use or disclose personal information for purpose other than those for which it was collected, except with the consent of the individual or as required by law. Nicewell Group will retain personal information only as long as necessary for the fulfillment of those purposes.

In certain circumstances, personal information can be collected, used or disclosed without the knowledge and consent of the individual (see Principles 3). In addition, Nicewell Group may disclose a customer’s personal information to:

l Another person for the development, enhancement, marketing or provision of any of Nicewell Group’s service

l A person who, in the reasonable judgement of Nicewell Group, is seeking the information as an agent of the customer

l A third party or parties, where the customer consents to such disclosure or disclosure is required by law

l A person engaged by Nicewell Group to perform functions on its behalf, such as research, data processing, payroll and legal services; or

l A person engaged by Nicewell Group to evaluate a customer’s credit status and credit reporting agencies.

Nicewell Group may disclose personal information about its employees:   

l For normal personal and benefits administration

l In the context of providing references regarding current or former employees in response to requests from prospective employers or

l Where disclosure is required by law

Only those Nicewell Group employees who require access for business reasons are granted access to personal information about customers and employees.

Nicewell Group will keep person information only as long as it remains necessary or relevant for the identified purposes or as required by law. Nicewell Group will maintain reasonable and systematic controls, schedules and practices for information will be destroyed, erased or made anonymous.

Data collected for web analytics purpose goes outside of China to Google servers and may be processed in any country where Google operates servers. Data may be subject to the governing legislation of that country. For further information about Google Analytics, please refer to Google Analytics terms of service. The information is not disclosed to an external third party service provider.

6. Accuracy

The personal information Nicewell Group maintains will be as accurate, complete and up-to-date as is necessary for which it is to be used.

Personal information used by Nicewell Group will be sufficiently accurate, complete and up-to-date to minimize the possibility that inappropriate information may be used to make a decision about a customer or employee.

Nicewell Group will update personal information about customers and employees as and when necessary to fulfill the identified purposes or upon notification by the individual

7. Safeguards

Nicewell Group will protect personal information through the use of security safeguards appropriate to the sensitivity of the information. The security safeguards will protect personal information against loss or theft, unauthorized access, disclosure, copying, use or modification, regardless of the format in which it is held.

Nicewell Group will make its employees aware of the importance of maintaining the confidentiality of personal information. Further, Nicewell Group will use care in disposing of or destroying personal information to prevent unauthorized parties from gaining access to the information.

8. Openness

Nicewell Group will make readily available to customers and employees specific information about its policies and practices relating to its management of personal information.

9. Individual Access

Nicewell Group will inform a customer or employee of the existence, use and disclosure of his or her or its personal information upon request, and will give the individual access to that information. A customer or employee will be able to challenge the accuracy and completeness of the information and have it amended as appropriate.

Upon request, Nicewell Group will afford customers and employees a reasonable opportunity to review the personal information in the individual’s file. Personal information will be provided in understandable form within a reasonable time and at a minimal or no cost to the individual. However, in certain situations, Nicewell Group may bot be able to provide access to all of the personal information it holds about a customer or employee. Nicewell Group will provide the reasons for denying access.

Upon request, Nicewell Group will provide an account of the use and disclosure of personal information and where reasonably possible, will state the source of the information. In providing an account of disclosure, Nicewell Group will provide a list of organizations to which it may have disclosed personal information about the individual when it is not possible to provide an actual list.

In order to safeguard personal information, a customer or employee may be required to provide sufficient identification information and to authorize access to the individual’s file. Any such information will be used only for this purpose.

Nicewell Group will promptly correct or complete any personal information found to be inaccurate or incomplete. Any unresolved differences as to accuracy or completeness will be noted in the individual’s file. Where appropriate, Nicewell Group will transmit to the third parties having access to the personal information in question any amended information or the existence of any unresolved differences.

A customer can obtain information or seek access to his or her or its individual files by contacting a designated representative at Nicewell Group’s head office. An employee can obtain information or seek access to his or her individual files by contacting his or her immediate supervisor within Nicewell Group.

10. Challenging Compliance

A customer or employee will be able to address a challenge concerning compliance with the above principles to the Privacy Official, Yiqing You, the person accountable for Nicewell Group’s compliance with this policy.

Nicewell Group will maintain procedures for addressing and responding to all inquires or complaints from its customers and employees about Nicewell Group’s handling of personal information. Nicewell Group will inform its customers and employees about the existence of these procedures as well as the availability of complaint procedures.

Yiqing You, the person accountable for Nicewell Group’s compliance with its policy, may seek external advice where appropriate before providing a final response to individual complaints.

Nicewell Group will investigate all complaints concerning its compliance with this policy. If a complaint is found to be justified, Nicewell Group will take appropriate measures to resolve the complaint including, if necessary, amending its policies and procedures. A customer or employee will be informed of the outcome of the investigation regarding his or her or its complaint.

Contact information:

Yiqing You

Nicewell Group

Address: 813# Yinxiu Road, Binhu District, Wuxi, China

Telephone:+86 510 82720475

Email: acc@wuxi-gumbase.com