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Privacy Policy

Last updated: May 2018

If you have any questions, comments or suggestions, please contact us by email at

Hold Engineering Ltd (HEL) understands how important your privacy is to you and are fully committed to protecting it. Please do not submit personal or private data to HEL before you have read, understood and agreed to this privacy policy.

We created this policy to help you understand:

1. How HEL uses your personal data
2. How HEL uses cookies and similar technologies
3. How HEL discloses your personal data
4. How to access or modify your personal data
5. How HEL protects your personal data
6. How HEL handles the personal data of children
7. HEL’s third party providers and their services
8. How your personal data is transferred internationally
9. How this policy is updated
10. International users
11. How to contact HEL

Please note that this policy applies solely to HEL consumer electronics, including feature phones, smartphones, tablets, home devices, data cards, computer applications, tools, software, websites and services that display or refer to this policy.

This policy describes how HEL handles your personal and private data and affirms its commitment to protecting your privacy. The policy does not address all possible data processing scenarios. Information about product- or service-specific data collection is issued by HEL in supplementary policies. It is recommended that you read both this policy and any supplements to fully understand HEL’s privacy policies for a specific product or service.

1. How HEL uses your personal data

Personal data is information that can be used on its own or in combination with other information to identify an individual. Such data is collected when you use HEL products or services and can include your name, telephone number and the location and date when products or services were accessed. HEL collects and uses your personal data solely for the purposes indicated in this policy. The following are examples of personal data we may collect and how we use it:

1.1. Personal data collected by HEL

We may collect some personal data, including your name, phone number, email address and location. Below are some examples of the types of personal data we may collect.

(a) Data you submit directly: Via the online contact form we may collect your name, email address, IP address, etc.


(b) Third party data: We may receive data about you from publicly and commercially available sources as permitted by law. We may also receive data about you from third party social networking services, such as when you log in to our websites using your Facebook or Twitter account.


(c) We ask for basic information from you in order to set up your intranet account. For example, we require individuals who sign up for an account to provide a username and email address – and that’s it. You may provide us with more information, like your name, but we don’t require that information to create your account.


1.2. How HEL uses your personal data


We may use your personal data to:


(a) Fulfil purchase orders; deliver, activate, or verify products or services; make changes upon your request; and offer technical support.


(b) Contact you; send you information about products and services that may be of interest; invite you to participate in HEL promotions and market surveys; or send you marketing information with your explicit consent. If you don’t want to receive such information, you can opt out at any time.


(c) Offer you a personalised user experience and personalised content.


(d) Carry out internal audits, data analysis and research to improve our services.


(e) Analyse the efficiency of our business operations and measure our market share.


(f) Improve customer communications and ensure that provide a secure, quality service to customers.


(g) Improve our loss prevention and anti-fraud programmes.


1.3. Collection and use of non-identifiable data


Non-identifiable data refers to data that cannot be used to identify an individual. For example, HEL may collect aggregated statistics, such as the number of visitors to its website. HEL collects this data to understand how people use its website, products and services. This allows HEL to improve its services to better satisfy customer needs. HEL may, at its own discretion, collect, use, process, transfer or disclose non-identifiable data for other purposes. We endeavour to keep your personal data and non-identifiable data separate and use each independently. If personal data is combined with non-identifiable data, it will be treated as personal data.


2. How HEL uses cookies and similar technologies

2.1. Cookies


To ensure that our websites function properly, we sometimes store small data files known as cookies on computers or mobile devices. A cookie is a simple text file that is stored on your computer or mobile device by a web server. Only the server that creates the cookie can retrieve or read the cookie’s contents. Each cookie is unique to your web browser or mobile application. Cookies usually contain an identifier, the site name and some numbers and characters. Cookies allow websites to store data, such as your user preferences.


Most websites or internet service providers enable cookies in order to improve their user experience. Cookies allow websites to remember users, either for a single visit (using a session cookie) or for repeated visits (using a persistent cookie). Cookies allow websites to store settings, such as language, font size and other viewing preferences for your computers or mobile devices. This means that user preferences do not need to be re-configured on each visit. If a website doesn’t use cookies, it will treat its users as new visitors each time they open a page. For example, if you log in on a website and move to another page, the website won’t recognise you and you will be logged out again. HEL does not use cookies for any purposes other than those specified in this policy. You can manage or delete cookies according to your preferences. For more information, see You can clear all cookies stored on your computer and most web browsers can be configured to block cookies. However, if you do so, you may have to manually change your user settings every time you visit our websites. For more information on how to change your browser settings, please visit the following links:


Internet Explorer
Google Chrome
Mozilla Firefox


2.2. Web beacons and pixel tags


In addition to cookies, we also use other similar technologies such as web beacons and pixel tags on our websites. For example, when you receive an email from HEL, it may contain a click-through URL which links to content on HEL’s website. If you click the link, the click-through is tracked by HEL to help us learn about your product and service preferences and improve our customer service. A web beacon is typically a transparent image that is embedded on a website or in an email. The inclusion of pixel tags in emails allows us to know if our emails have been opened. If you do not want your activities to be tracked in such a way, you may unsubscribe from HEL mailing lists at any time.


2.3. Do Not Track


Many web browsers have a Do Not Track feature, which issues Do Not Track requests to websites. Currently, the main Internet standards organisation has no policy governing how websites should behave when they receive such requests. However, all HEL websites do respect the Do Not Track option if it is enabled in your browser.


3. How HEL discloses your personal data

HEL does not sell your personal data to third parties. However, HEL may disclose your personal data under the following circumstances:


3.1. Disclosures with explicit consent


After obtaining your explicit approval, HEL may share your personal data with other parties.

3.2. Disclosures to NIS Group companies


Your personal data may be shared with HEL’s sister companies. As a matter of policy, we will only disclose data that is necessary.

3.3. Disclosures on legal or reasonable grounds

HEL may disclose your personal data if required by the law, legal proceedings, litigation or public and governmental authorities.


4. How to access or modify your personal data

Under HEL’s terms and conditions, you can manage your personal data, such as your account information, at any time. You should ensure that all personal data submitted is accurate. HEL will make reasonable efforts to keep your personal data accurate, complete and up-to-date. You have a right to access your personal data, subject to some legal exceptions. If you would like to exercise your right to access data, please inform us by email at For security reasons, you may be required to put your request in writing. You also have the right to delete or amend any personal information about you that we hold. HEL will delete or amend such information upon your request. To make such a request, you can contact us by email at We may decline to process requests if we have a reasonable basis to believe that they are made in bad faith, are impractical or if access is not otherwise required by local law.


5. How HEL protects your personal data

HEL takes personal data security seriously. We follow industry-standard practices to safeguard your personal data against unauthorized access, disclosure, use, modification, damage or loss. We take all reasonably practicable steps to protect your personal data. For example, we use encryption to ensure data confidentiality; we use trusted protection mechanisms to protect data from malicious attacks; we deploy access control mechanisms to ensure only authorized personnel can access personal data; and we raise awareness among employees about the importance of protecting personal data through security and privacy protection training sessions. We take all reasonably practicable steps to only collect relevant personal data. We only retain your personal data for the period necessary to fulfil the purposes outlined in this policy, unless a longer retention period is required or permitted by law. While we take the utmost care to protect your personal data, please note that no security measures are completely infallible.


6. How HEL handles the personal data of children

HEL will never knowingly collect the personal data of children. If it was discovered that data had been collected, it would be deleted as soon as possible.


7. Third party providers and their services

To ensure a smooth browsing experience, you may be served content or web links from third parties external to HEL and our partners (“third parties”). HEL does not have control over such third parties. You can choose whether or not to access links, content, products and services offered by third parties. HEL has no control over the privacy and data protection policies of third parties, which are not governed by this policy. Before submitting your personal information to third parties, please refer to their respective privacy protection policies.


8. How your personal data is transferred internationally

HEL products and services are delivered through resources and servers located around the world. This means your personal data may be transferred to or accessed from other jurisdictions which are outside the country where you use our products or services. These jurisdictions may have different data protection laws, or such laws may not even exist. In such cases, HEL will ensure that a similar and adequate level of protection is afforded to your data as required by all applicable laws and regulations. For example, HEL may request your consent to transfer personal data across borders or implement security measures like data anonymisation prior to cross border data transfers.


9. How this policy is updated

HEL reserves its right to update or amend this policy from time to time. HEL will notify you of the changes through various channels. Where changes are made to our privacy policy, we will post the updated privacy policy on this page. We may also issue you with a separate notice (e.g. an electronic notification) to inform you of any changes to our privacy policy.


10. How to contact HEL

If you have any questions, comments or suggestions, please contact us by email at

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