Privacy policy | KELY

Privacy Policy

How and why does KELY Support Group collect personal data?

KELY Support Group collects personal data when carrying out its work. In most cases it relates to data that he requests from the person concerned or that the person concerned provides on his own. Think of a first telephone conversation between KELY Support Group and a (potential) customer or a situation where a (potential) customer sends an e-mail to KELY Support Group. KELY Support Group will work as carefully as possible when processing personal data. An essential part of that care is transparency. It is important that third parties and those involved understand the way in which personal data are being used and the reasons behind it. That is why this statement has been drawn up.

Who is KELY Support Group exactly?

In many cases, KELY Support Group is responsible for the processing of personal data. It is registered at the Companies Registry under number 0632647 and established at the 2/F East Wing, 12 Borrett Road in Central Hong Kong, contactable on phone number 2521 6890 and by email at

Does KELY Support Group have a Data Protection Officer?

KELY Support Group did not appoint a Data Protection Officer.

Which personal data does KELY Support Group process and why does it do this?

KELY Support Group processes various types of personal data for various reasons. The data that is processed the most:

  • Identification data (name, e-mail address, contact person, phone number, corporate phone number)
  • Location data (postal and / or corporate address)
  • Financial data (bank account number, payment details)

In the case of a job application, KELY Support Group will process additional information, namely:

  • Composition of family, education level and job experience(s)

The main purposes of the above data processing are for: (i) e-newsletter subscription; (ii) volunteer enrollment; (iii) online donation processing; (iv) online purchase processing (v) issuance of receipt; (vi) conducting market research for statistical purposes.

Is KELY Support Group allowed to process those details?

KELY Support Group processes personal data where necessary in order to establish or execute an agreement with a customer and / or a supplier. This is the case, for example, when a quote is requested or when an order is placed. Furthermore, KELY Support Group processes personal data if its own interests justify it. This will be the case if it is reasonably impossible for KELY Support Group to carry out its work without processing this data. Finally, in some cases KELY Support Group also requests permission to use the data. The formal legal grounds for processing are therefore:

  • that processing is necessary for the performance of an agreement in which the person a part is, or is made at the request of the person concerned for the conclusion of an agreement.
  • that processing is necessary for the representation of the legitimate interests of KELY Support Group (or a third party)
  • that the person concerned has given permission for the processing

With regard to legal grounds (ii), it applies in all cases to processing operations that are necessary for KELY Support Group to be able to realize its services. It simply cannot do its work (communicating with the customer, assembling documents, offering support, sending out invoices, etc.) without using the personal data of the customer. The importance that KELY Support Group has in these processing operations is therefore considerable. This is especially true now that there is no possibility for KELY Support Group to achieve its goals without making use of that data. KELY Support Group believes that its importance must be given priority when weighed against the interest of the person concerned. Firstly because it knows from experience that such processing as a rule does not encounter any objections. That is why it can take that as a starting point. Secondly, because KELY Support Group only uses the data that he actually needs to achieve his goal. Thirdly, because the relevant data is not kept any longer than necessary. As a result, KELY Support Group limits the infringement of the rights of the person concerned to the minimum. With regard to category (iii), permission given can be withdrawn at any time without giving any reason. The permission to process data via the website is requested when the website is visited.

Do these personal data end up with others?

In some cases, KELY Support Group will share personal data with parties with which it cooperates. These are so-called 'processors'. KELY Support Group has concluded agreements with those processors. These serve to ensure that those processors (like KELY Support Group himself) handle this information carefully. For example, a processor is obliged under the agreement to ensure proper security, to deal confidentially with those data and to destroy the data.

KELY Support Group does not intend to share personal data with parties other than processors.

At most, it foresees that, in a single case, information will be shared with (another) employee of the customer or with parties that are in direct contact with the customer.

Will the personal data remain in Europe?

This is the context of the European Economic Area (EEA). It consists of the countries of the EU, supplemented by Norway, Liechtenstein and Iceland. All countries that fall outside it are considered a 'third country'. KELY Support Group does not transmit personal data to third countries. The personal data therefore remains in Europe. If in an exceptional case there is still a transfer to a 'third country' then this will only happen to a country of which it has been explicitly established at European level that an appropriate level of personal data is guaranteed there.

How long will these data be kept?

KELY Support Group stores the data collected by it for different time periods, depending on the category of data and the way in which they were collected. The precise terms are included in the register of processing activities that KELY Support Group has drawn up. When setting the applicable terms, KELY Support Group is initially based on statutory (minimum) periods. Think of the statutory duty to keep accounting information. Furthermore, where possible, KELY Support Group has sought to connect to the storage periods included in the Wbp Exemption Decision. For example, with regard to the contact details of the customer, a storage period of up to one year after termination of the relationship between the parties applies. Finally, KELY Support Group was guided by its interests and those of its customers when setting the storage periods. For example, it can be important for both parties that documents in which (further) agreements have been recorded are kept for more than two years. If such documents (such as mail correspondence, for example) contain personal data, they will then also be kept.

With regard to the data collected via the cookies on the website, the storage periods as described in the Cookie Policy apply.

What rights do I have?

According to the law, you are a 'person concerned' and those concerned have a number of specifically defined legal rights. You can submit a request to KELY Support Group to view, receive, change or delete your personal data. You can also object to the (further) processing of your data. If KELY Support Group processes your personal data on the grounds of your consent, you can revoke that permission at any time. For all these matters and for other questions, please contact:

KELY Support Group Limited
2/F East Wing
12 Borrett Road
Central, Hong Kong
Tel: 2521 6890
Fax: 2521 6853

KELY Support Group will respond to your message within a month.

If you believe that KELY Support Group is acting in violation of applicable laws and regulations on personal data, you can submit a complaint to the Privacy Commissioner for Personal Data, Hong Kong.

Is there automated decision-making with KELY Support Group?

No automated decision making take place with KELY Support Group.

What else should I know?

  • KELY Support Group does not have an automated system
  • In order to be able to implement a proper privacy policy, KELY Support Group has drawn up a register of all the ways in which it processes personal data. Per processing, among other things, the purpose, the grounds and the storage period are included.
  • KELY Support Group has taken appropriate technical and organizational measures to protect your personal data. A description of this is also included in the processing register. KELY Support Group periodically assesses whether these measures are sufficient.
  • KELY Support Group's privacy policy also looks at matters that are independent of its relationships with its customers. For example, there is also a storage period for applicant's data.
  • From time to time it will be necessary to change this Statement. KELY Support Group has the right to do so. We advise you to occasionally check this Statement for possible changes.

Version 25 May 2018