1. Privacy & Cookie policy

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

  • Address: Room 3602, China Resources Building, 26 Harbour Road, Wanchai,
  • City: Hong Kong
  • Country: Hong Kong
  • Phone: +852 2 827 19 33
  • E-mail: info@smr.hk

The representative of SMR in the European Union is Specialty Metals Resources SA with address and contact details as follows:

  • Address: Rue de Tenbosch 42 A
  • City: Brussels 1050
  • Country: Belgium
  • Phone: +32 2 580 5800
  • E-mail: info@smr.hk

Your privacy is very important to us. That is why we want to inform you as a Site 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 and cookie policy  applies to all personal data collected and 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: collecting, organizing, structuring, storing and application of data.

In processing your personal data SMR is required to act in accordance with applicable legislation including the European Union General Data Protection Regulation (Regulation 2016/679) and always in the most transparent way possible.

This privacy and cookie  explains what information SMR collects from you when you use our website, what SMR uses the information for and explains your rights and how they can be exercised.

1.1.      Controller

SMR will act as controller for personal data.

1.2.       Your personal data

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

1.3.      Processing personal data

1.3.1.           What data does SMR collect?

SMR collects personal data  from 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 and potential clients, suppliers, employees and subcontractors.

1.3.2.           How does SMR collect data?

You directly provide to SMR most of the data that we collect.  We collect data and process data when you:

  • Use or view our website via your browsers cookies
  • Place orders for any of our products

1.3.3.           Why does SMR collect and process personal data?

SMR collects and processes personal data for the following purposes:

  • Providing services to customers: this is necessary in order to be able to provide the requested services including communications with customers regarding actual or potential contracts. These data may vary depending on the services provided.
  • Financial administration: these data are necessary for accounting and invoicing purposes in relation to customers and suppliers with whom SMR has commercial relations.
  • 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) based on existing commercial relationships.
  • 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.

1.3.4.           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 and public authorities.   In some instances it may be necessary for  SMR to share data with them. We require where possible that these third parties to comply with all applicable privacy legislation. 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. Similarly, the website may contain links to other sites.

These social media providers are Facebook, Instagram, LinkedIn, Google, Youtube. Visitor statistics of the website are tracked via Google Analytics.  Similarly, the website may contain links to other sites.

It is your decision whether or not you use these links and if you do  you must consult the privacy policy of such other websites. 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.

1.3.5.           How does SMR store and secure your personal data?

SMR securely stores your personal data. Various security measures (e.g. SSL) have been developed and configured to keep your personal data safe, correct and up-to-date.

1.3.6.           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, accounting and taxation information).

1.3.7.           Website

When you post a comment on our website, this comment and related data will be stored in our database for a limited period.

Users who have registered on our website (if applicable) can view, change or delete their personal information in their user profile.

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

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 receiving marketing and can opt out at any time.

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 any EU Member State.  The relevant Commission of SMR’s EU representative is as follows

Commission for the Protection of Privacy, Belgium

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.

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.

Cookies on the SMR website

Name Type Goal Time Details
Cookie GDPR SMR Remembers your cookie preferences 30 days 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

1.7.2.           How to manage 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. Gerald Van Lede
  • 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 30/06/2020 by SMR.