Privacy policy

Gemcore Global ("we", "us", or "our") is brand-name belonging to a company Sun Lok Commerce Limited, incorporated in Hong Kong, with registered offices at Unit 903D, Cameron Commercial Centre, 458 Hennessy Road, Causeway Bay, Hong Kong.

We operate a website at this domain and conduct commodity trading and related services. This Privacy Policy explains how we collect, use, store, and protect personal data provided to us through this website and through our business activities.

We may collect the following categories of personal data:

• Contact and identity data - name, job title, company name, email address, telephone number, and postal address when you submit an enquiry or communicate with us.
• Enquiry and transaction data - information about the commodities, services, or transactions you enquire about, including specifications, volumes, and requirements.
• Communication data - records of correspondence and communications between you and Gemcore Global.
• Technical data - IP address, browser type, operating system, and pages visited when you use our website, collected through standard server logs and any analytics tools we operate.

We do not knowingly collect data from individuals under 18 years of age.

We use the personal data we collect for the following purposes:

• To respond to your enquiries and communicate with you about products and services.
• To process, manage, and fulfil trading transactions and service engagements.
• To fulfil legal and regulatory obligations applicable to our business in Hong Kong and other relevant jurisdictions.
• To maintain records of our business activities and communications.
• To improve the operation and content of our website.
• To send service-related communications, where required by an ongoing business relationship.

We will not use your data for unsolicited marketing or sell it to third parties for marketing purposes.

We process personal data on the following legal bases:

• Contractual necessity - processing required to perform a contract with you or to take steps at your request prior to entering a contract.
• Legitimate interests - processing necessary for our legitimate business interests, including managing enquiries, maintaining business records, and improving our services, where these interests are not overridden by your rights.
• Legal obligation - processing required to comply with applicable law, regulation, or court orders.
• Consent - where we have obtained your explicit consent for a specific processing activity.

We do not sell or rent personal data to third parties. We may share personal data in the following limited circumstances:

• Service providers - we may engage trusted third-party service providers (such as IT infrastructure, email, or inspection service providers) who process data on our behalf and are bound by appropriate data processing agreements.
• Transaction counterparties - where necessary to complete a trading transaction or service engagement you have requested, relevant contact and specification data may be shared with suppliers, buyers, or inspection bodies.
• Legal requirements - we may disclose data where required to comply with applicable laws, regulations, legal process, or enforceable governmental requests.
• Business transfers - in the event of a merger, acquisition, or sale of business assets, personal data may be transferred as part of that transaction.

Where data is transferred outside Hong Kong, we ensure appropriate safeguards are in place consistent with applicable data protection requirements.

We retain personal data for as long as is necessary to fulfil the purposes for which it was collected, and to comply with our legal, regulatory, and contractual obligations.

Enquiry data where no transaction results is typically retained for up to 2 years. Transaction and counterparty data is retained for a minimum of 7 years in accordance with standard commercial record-keeping requirements under Hong Kong law. Technical website data is retained for up to 12 months.

When data is no longer required, it is securely deleted or anonymised.

Subject to applicable law, you may have the following rights in relation to your personal data:

• Access - the right to request a copy of personal data we hold about you.
• Correction - the right to request correction of inaccurate or incomplete data.
• Deletion - the right to request deletion of your personal data in certain circumstances.
• Objection - the right to object to processing based on legitimate interests in certain circumstances.
• Restriction - the right to request restriction of processing in certain circumstances.

To exercise any of these rights, please contact us at info@gemcoreglobal.com. We will respond within a reasonable timeframe and in accordance with applicable law.

Our website may use cookies and similar technologies to support the operation of the site and to collect standard internet log information and visitor behaviour information. Cookies are small text files placed on your device by your browser.

We use only essential cookies necessary for the website to function correctly. We do not use third-party advertising cookies or tracking cookies. You may configure your browser to refuse cookies, though this may affect certain website functionality.

We take reasonable technical and organisational measures to protect personal data against unauthorised access, loss, destruction, or alteration. These measures include secure server infrastructure, restricted access controls, and regular review of our security practices.

While we take data security seriously, no method of internet transmission or electronic storage is completely secure. We cannot guarantee absolute security of data transmitted to or stored on our systems.

If you have any questions about this Privacy Policy or how we handle your personal data, please contact us:

• Email: info@gemcoreglobal.com
• Post: Gemcore Global, Unit 903D, Cameron Commercial Centre, 458 Hennessy Road, Causeway Bay, Hong Kong

This Privacy Policy may be updated from time to time. The date of the most recent revision is shown at the foot of the table of contents. We encourage you to review this policy periodically.