1. WHO AM I?
This website (“Site”) is operated by Meimanrensheng Limited, a company registered in Hong Kong under registration number 1787026 (“Meimanrensheng”, “MMRS”, “Livingalifeincolour”, “we”, “me”, “our” and/or “I”). You can contact me as indicated under the “Contact” section below.
The data controller responsible for your personal data is Meimanrensheng company with whom you contract as a user of this site.
2. WHAT IS THIS PRIVACY POLICY IS FOR?
This privacy policy (“Privacy Policy”) applies to personal data that I collect from you as a user of this Site (“you” or “your” being interpreted accordingly). It provides information on what personal data I collect, why I collect the personal data, how it is used and the lawful basis on which your personal data is processed, and what your rights are under the applicable data protection and privacy laws, including the General Data Protection Regulation (“GDPR”) which will become applicable to me and you as of 25 May 2018.
‘Personal data’ as used in this Privacy Policy means any information that relates to you from which you can be identified.
By using my Site or submitting your personal data you are taken to accept the terms of this Privacy Policy, so please read it carefully.
3. PERSONAL DATA I COLLECT
I collect the following personal data about you in order to better tailor the content on this site:
• Subscription: The personal details you provide when submitting a subscription application. This includes your name and e-mail address.
• Other Information: Personal details you choose to give when corresponding with me by e-mail, participating in user surveys or otherwise visiting and interacting with this Site or any other websites I operate, and personal data that you provide.
4. AUTOMATICALLY COLLECTED PERSONAL DATA
• Log Data: When you visit my Site, our servers record information (“log data”), including information that your browser automatically sends whenever you visit the Site. This log data includes your Internet Protocol (“IP”) address (from which I understand the country you are connecting from at the time you visit the Site), browser type and settings, the date and time of your request.
• Our Site uses cookies (small text files placed on your device) and similar technologies to distinguish you from other users. This is to provide you with a good user experience when you browse our Site and allows us to improve its features.
5. HOW I USE YOUR PERSONAL DATA
I use your personal data in the following ways:
• To acknowledge, confirm and deal with your subscription. Such use of your data is necessary in order to implement your request to become a subscriber.
• Where you are a subscriber, to send you blog posts and such use is necessary to respond to or implement your request and for the performance of the subscription between us.
• To contact you in connection with user surveys and use any information you choose to submit in response, provided that you gave us your consent to being contacted in this way at the time you provided me with the personal data.
• As necessary for certain legitimate business interests, which include the following:
o where I am asked to deal with any enquiries or complaints you make.
o to administer my Site, to better understand how visitors interact with my websites and ensure that my Site is presented in the most effective manner for you and for your computer/device.
o to conduct analytics to inform my marketing strategy and enable me to enhance and personalise the experience I offer to my users and my communications, including by creating user profiles to enable personalised communications.
o if you ask us to delete your data or to be removed from my lists, to keep basic data to identify you and prevent further unwanted processing.
o I may anonymise, aggregate and de-identify the data that I collect and use such anonymised, aggregated and de-identified data for my own internal purposes, including sharing it with my current and prospective agents and other third parties for commercial, statistical and market research purposes, for example to allow those parties to analyse patterns among groups of people, and conducting research on demographics, interests and behavior.
o for internal business/technical operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes and as part of our efforts to keep my Site, network and information systems secure.
o to (a) comply with legal obligations, (b) respond to requests from competent authorities; (d) protect my operations or those of any of my affiliated businesses; (e) protect my rights, safety or property, and/or that of my affiliated businesses, you or others; and (f) enforcing or defending legal rights, or preventing damage.
• I may use your personal data for other purposes which you have consented to at the time of providing your data.
As used in this Privacy Policy, “legitimate interests” means the interests of Meimanrensheng and our affiliated businesses in conducting and managing my organisation. When I process your personal data for my legitimate interests, I make sure to consider and balance any potential impact on you, and your rights under data protection laws. My interests do not override your interests. I will not use your personal data for activities where my interests are overridden by the impact on you, unless I have your consent or those activities are otherwise required or permitted to by law. You have the right to object at any time to processing of your personal data that is based on my legitimate interests, on grounds relating to your particular situation (for more information on your rights, please see “Your Data Protection Rights” section below).
6. DISCLOSURE OF YOUR INFORMATION
I share your personal data with third parties in the following situations:
• Service Providers: I sometimes hire selected third parties who act on my behalf to support my operations, such as (i) IT suppliers and contractors (e.g. data hosting providers or delivery partners) as necessary to provide IT support and enable me to provide services available on this Site, (ii) web analytics providers, (iii) providers of digital advertising services and (iv) providers of CRM, marketing and sales software solutions. Pursuant to my instructions, these parties may access, process or store your personal data in the course of performing their duties to me and solely in order to perform the services I have hired them to provide.
• Business Transfers: if I sell our business or our company assets are acquired by a third party personal data held by me about our members, membership applicants or customers may be one of the transferred assets.
• Administrative and Legal Reasons: if I need to disclose your personal data (i) to comply with a legal obligation and/or judicial or regulatory proceedings, a court order or other legal process. (ii) to enforce applicable contract terms that you are subject to or (iii) to protect me or my contractors against loss or damage. This may include (without limit) exchanging information with the police, courts or law enforcement organisations.
7. PERSONAL DATA TRANSFERS
Your personal data will be transferred to and stored in countries other than the country in which the information was originally collected, including the United States and other destinations outside the European Economic Area (“EEA”), to my service providers and affiliated businesses for the purposes described above.
Please note that the countries concerned may not provide the same legal standards for protection of your personal data that you have in the United Kingdom or EEA. Where I transfer your personal data to countries outside of the EEA I will take all steps to ensure that your personal data will continue to be protected. I will implement appropriate safeguards for the transfer of personal data to our service providers in accordance with the applicable law, such as relying on our service providers’ Privacy Shield certification or implementing standard contractual clauses for data transfers. I have implemented data transfer agreements pursuant to applicable data protection law in order to implement appropriate safeguards for the transfer of personal data to Meimanrensheng companies in countries outside the EEA. If you would like to receive more information on the safeguards that I implement, including copies of relevant data transfer contracts, please contact us as indicated below.
8. PERSONAL DATA RETENTION
I will keep your personal data only for as long as is reasonably necessary for the purposes outlined in this Privacy Policy, or for the duration required by any legal, regulatory, accounting or reporting requirements, whichever is the longer. In particular, I retain user records for six years after termination of your subscription. I retain information submitted through the Site and the other websites I operate for two years following account closure or contact with you, as applicable.
To determine the appropriate retention period for your personal data, I consider the amount, nature, and sensitivity of the personal data, the purposes for which I process your personal data, applicable legal requirements or operational retention needs, and whether I can achieve those purposes through other means.
Upon expiry of the applicable retention period I will securely destroy your personal data in accordance with applicable laws and regulations. In some circumstances I may anonymise your personal data so that it can no longer be associated with you, in which case it is no longer personal data.
9. YOUR PERSONAL DATA PROTECTION RIGHTS
Certain applicable data protection laws give you specific rights in relation to your personal data. In particular, if the processing of your personal data is subject to the GDPR, you have the following rights in relation to your personal data:
• Right of access: If you ask me, I will confirm whether I are processing your personal data and, if so, provide you with a copy of that personal data along with certain other details such as the purpose of the data processing.
• Right to rectification: If your personal data is inaccurate or incomplete, you are entitled to ask that I correct or complete it. If I shared your personal data with others, I will tell them about the correction where possible. If you ask me, and where possible and lawful to do so, I will also tell you with whom I shared your personal data so you can contact them directly.
• Right to erasure: You may ask me to delete or remove your personal data, such as where our legal basis for the processing is your consent and you withdraw consent. If I shared your data with others, I will tell them about the erasure where possible. If you ask us, and where possible and lawful to do so, I will also tell you with whom I shared your personal data with so you can contact them directly. I may continue processing personal data where this is necessary for a legitimate interest in doing so, as described in this Privacy Policy.
• Right to restrict processing: You may ask me to restrict or ‘block’ the processing of your personal data in certain circumstances, such as where you contest the accuracy of the personal data or object to us processing it. I will tell you before I lift any restriction on processing. If I shared your personal data with others, I will tell them about the restriction where possible. If you ask me, and where possible and lawful to do so, I will also tell you with whom I shared your personal data so you can contact them directly.
• Right to data portability: You have the right to obtain your personal data from me that you consented to give me or that was provided to me as necessary in connection with your subscription. I will provide you with your personal data in a structured, commonly used and machine-readable format. You may reuse it elsewhere.
• Right to object: You may ask me at any time to stop processing your personal data, and I will do so:
o If I are relying on a legitimate interest to process your personal data — unless I demonstrate compelling legitimate grounds for the processing or
o If I are processing your personal data for direct marketing.
• Right to withdraw consent: If I rely on your consent to process your personal data, you have the right to withdraw that consent at any time. This will not affect the lawfulness of processing of your data before I received notice that you wished to withdraw your consent.
• Right to lodge a complaint with the data protection authority: If you have a concern about our privacy practices, including the way I handled your personal data, you can report it to the UK data protection authority (the Information Commissioner’s Office or ICO), or, as the case may be, any other competent data protection authority of an EU member state that is authorised to hear those concerns (you may find EU Data Protection Authorities’ contact information here.)
If you wish to exercise any of these rights please contact me as described in the “Contact” section below. I may also need to ask you for further information to verify your identity before we can respond to any request.
10. CHANGES TO MY PRIVACY POLICY
Any changes I may make to my Privacy Policy in the future will be posted on this page. Please check back frequently to see any updates or modifications. If required by the applicable law, I will notify you of any material or substantive changes to this Privacy Policy.
11. CONTACT
Questions, comments or requests regarding this Privacy Policy should be addressed to [email protected]