1. Privacy & Cookie policy

The website www.smr.hk   (hereafter referred to as the “website”) is owned by Specialty Metals Resources SA, hereafter referred to as “SMR” or  “We”

  • Address: Rue de Tenbosch 42A
  • City: 1050 Brussels
  • Country: Belgium
  • Phone: T +32 2 580 580 0
  • E-mail: info@smr.hk
  • VAT Number: 465.938

Your privacy is very important to us. That is why we want to inform you as a user about the use of your personal data in an open and transparent manner. SMR reserves the right to amend this privacy policy. Changes will be published on this website page.

This privacy statement applies to all personal data processed by SMR. Personal data are all types of information relating to an identified or identifiable natural person. In other words, all data that can be traced back to your person. Processing is understood to mean the following: processing, collecting, organizing, structuring, storing, …

SMR strives to process your personal data in accordance with applicable legislation such as the EU GDPR/AVG legislation (Regulation 2016/679) and always in the most transparent way possible.

This privacy statement explains what information SMR collects, what SMR uses the information for and to whom this information is passed on. We also explain your rights and how they can be exercised.

1.1.      Controller

SMR will act as controller for personal data.

1.2.      User

The user, hereafter referred to as ‘user”, “customer”, “you”, “your” or any legal person whose personal data is processed by SMR.

1.3.      Process personal data

1.3.1.           Whose personal data does SMR process?

SMR processes personal data of companies and/or private individuals with whom SMR has, has had, or wishes to have a direct or indirect relationship in the future. This includes data of current clients, suppliers, clients, subcontractors, employees, volunteers as well as potential new clients and employees.

1.3.2.           Why does SMR process personal data?

SMR collects and processes personal data for the following purposes:

  • Provide services to customers: these are necessary in order to be able to provide the requested services. These data may vary depending on the services provided.
  • Financial administration: these data are necessary for accounting and invoicing purposes.
  • Maintaining customer contacts: sending emails (e.g. Newsletters) for products and services that may be of interest to our customers and potential customers (direct marketing).
  • User information: on our website to monitor responses, security, availability, and performance.
  • Third parties: necessary in order to carry out the cooperation with third parties.
  • Recruitment purposes: necessary for the recruitment of new employees.

As a user, you always choose which data you share with SMR.

1.3.3.           With whom does SMR share your personal data?

Under no circumstances will your data be shared with third parties for commercial purposes. SMR cooperates with third parties for IT related matters (e.g. Hosting), accounting, administration, communication, security, services, public authorities, … which in some cases requires SMR to share data with them. We expect these third parties to comply with the applicable privacy legislation (GDPR/AVG). They may not use this data for any purpose other than that for which it was shared with them.

This website uses social media plugins that allow users to be redirected to our social media channels or that allow users to share messages from the website on social media.

These social media providers are Facebook, Instagram, LinkedIn, Google, Youtube. Visitor statistics of the website are tracked via Google Analytics. If these links or the website is used, the above mentioned parties may collect the user’s personal data. SMR is not responsible for how these parties process the personal data of the users. In this case, they will act as data controller and will be responsible for this.

No personal data will be transferred outside the European Union.

1.3.4.           How does SMR secure your personal data?

SMR does the utmost to protect your personal data as much as possible. Various security measures (e.g. SSL) have been developed and configured to keep your personal data safe, correct and up-to-date. At all times SMR tries to avoid unauthorized access, disclosure or deletion of data.

1.3.5.           How long does SMR keep your data?

SMR stores your data only for the execution of its activities and services. It is possible that your data may be kept longer because of legal obligations (e.g. invoicing). After a maximum of 10 years after the end of the customer relationship, all data will be deleted.

1.3.6.           Website

When you post a comment on our website, this comment and related data will be stored in our database for a maximum of 10 years. This way we can automatically recognize new reactions and approve them immediately, so they do not have to be moderated.

Users who have registered on our website (if applicable) can view, change or delete their personal information in their user profile. It is not possible to delete the user name. Administrators of the website can also consult and change this information.

To avoid SPAM, SMR also uses automatic SPAM detection: “reCAPTCHA” provided by Google: https://policies.google.com/privacy  and  https://policies.google.com/terms

When users submit a contact form or send an e-mail, the wipes are stored until they are fully processed or for a maximum of 10 years.

1.4.      Rights

The customer’s or user’s rights are explained below:

  • Access: the customer can receive information about the processing of his or her personal data and can obtain a free copy of this personal data.
  • Rectification: if a customer believes that his or her personal data is incorrect or incomplete, the customer may ask for it to be corrected.
  • Deletion: the customer can ask to delete his or her personal data.
  • Restriction: the customer can ask to limit the processing of his or her personal data.
  • Objection: the customer can object to the processing of his or her personal data.
  • Withdrawal of your consent: if the customer has given his or her consent for the processing of personal data, he or she can always withdraw this consent again.
  • Data transferability: the customer always has the right to have the data transferred to a third party. This is subject to the condition that the legal obligations always apply and that this must be technically possible.

By means of a written request, the user can assert his or her rights. The contact details of the data controller are listed under the point “Contact details”. A condition is that the user proves his or her identity (e.g. by means of a copy of his or her identity card).

The user can only invoke the right of deletion in the following cases:

  • The personal data are no longer necessary for the purposes of processing.
  • The user has withdrawn his consent to work
  • The user exercises his right to oppose direct marketing
  • The personal data have no legal basis for further processing or have been the subject of unauthorized use.
  • Personal data must be deleted in order to comply with legal obligations

The user may NOT invoke the right of deletion in the following cases:

  • The processing of personal data is necessary for the right to information and freedom of expression
  • The processing of personal data is necessary in order to comply with legal regulations.
  • The processing of personal data is necessary for the public interest (public health)
  • The processing of personal data is necessary for archiving purposes
  • The processing of personal data is necessary for the exercise or defense in a legal case

In order to exercise these rights, the customer can contact SMR. See contact details below.

1.5.      Marketing

SMR uses the personal data it has legally acquired to inform its customers (direct marketing). The customer always has the right to object to any processing of his or her personal data. In order to exercise these rights, customers can contact info@smr.hk or by mail.

1.6.      Complaint

The customer always has the right to submit a complaint to the Commission for the Protection of Privacy:

1.7.      Cookies

This website uses cookies that store your preferences and therefore make navigating on this website easier.

1.7.1.           Cookies?

Cookies are small text files who save the surfing behavior of users of this website. These cookies are stored on your computer. These cookies are stored in the temporary files of your web browser and can have different purposes: technical cookies, temporary cookies and tracking cookies. When visiting a website, the browser checks whether cookies are present and what the settings are (e.g. choice of language).

Thanks to these cookies SMR can analyze visitor behavior and improve the website. In this way, we ensure that you see even more relevant information. In order to be able to use the website optimally, it is advisable to enable cookies. Some cookies cannot be disabled because they ensure the correct functioning of the website. Other cookies (analysis) can be disabled.

1.7.1.           Types of cookies

There are different types of cookies:

  • Essential cookies: these cookies are necessary for this website to function (for performance reasons).
  • Non-essential cookies/Analytics cookies: these cookies collect information about the behavior of users on the website.
  • Non-essential cookies/Marketing cookies: these cookies follow the behavior of the users of the website and use this information to subsequently display advertisements tailored to the user.

1.7.2.           Cookies on the SMR website

Name Type Goal Time Details
Cookielawinfo-checkbox-non-necessary SMR Remembers your cookie preferences 1 jaar SMR
Cookielawinfo-checkbox-necessary SMR Remembers your cookie preferences 1 jaar SMR
_ga Google Analytics, analytical cookie These cookies collect information about the behavior of users on the website. 2 years after website visit https://policies.google.com/privacy
_gid Google Analytics, analytical cookie These cookies collect information about the behavior of users on the website. 24 hours after website visit https://policies.google.com/privacy
_gat Google Analytics, analytical cookie These cookies collect information about the behavior of users on the website. 1 minute after website visit https://policies.google.com/privacy

1.7.3.           How to disable these cookies?

As a user, you can disable cookies, delete them or manage the settings. It may be that in some cases the website can no longer function correctly.

Below you will find more information about disabling cookies:





1.8.      Contact details

SMR will handle your personal data with care. Should something go wrong, we will inform you as soon as possible and do everything we can to limit the damage. Leakage of your personal data due to data theft or a data breach can under no circumstances give rise to a claim for damages against SMR.

If you have any questions about the use of your personal data as described in this privacy statement, please contact us using the details below. These contact details can also be used to exercise your rights.

  • Address: t.a.v. Data Protection Officer, Rue de Tenbosch 42A, City: 1050 Brussels
  • E-mailaddress: info@smr.hk

SMR will process each written request within the period of one month.

Click here to view the disclaimer.

Last update on 27/06/2020 by SMR.