Privacy Policy — CKW SPOT

Go directly to Account and Data Deletion Requests

This Privacy Policy explains how Kin Wing Engineering Company Limited (“we”, “us”, or the “Company”) collects, uses, stores, discloses, and protects personal data in connection with the CKW SPOT mobile application (the “App”). We handle personal data in accordance with the Hong Kong Personal Data (Privacy) Ordinance (Cap. 486) (“PDPO”).

CKW SPOT is an internal corporate operational application for pre-authorized employees, site personnel, and contractors. It is not intended for general public use.

By accessing or using the App, you acknowledge that you have been provided with this Privacy Policy. Where a device permission is required, the App will request that permission through the applicable operating-system permission process.

1. Personal Data and Device Permissions We Use

We limit the collection and use of personal data and device permissions to information reasonably necessary for authentication, internal operations, work-record submission, security, and notification delivery.

Category	Examples	Purpose and Collection Method
Account and Identity Data	Name, work email address, staff or contractor code, organizational account identifier, assigned project or site access rights	Used to authenticate authorized users, maintain secure sessions, identify submitted work records, and control access to projects, sites, and App functions. Account details are provisioned or approved internally and may be received through Microsoft Entra ID single sign-on.
Camera Images and Scanned Work Data	Images, documents, labels, forms, records, or other work-related information captured using the device camera	Used to scan, record, or upload work-related data within the App. Camera access is requested only when the user actively selects a camera, scanning, capture, or upload function. The App does not continuously access the camera in the background.
Work Content and Operational Records	Issue reports, inspection records, site updates, safety forms, comments, workflow entries, scanned information, and related attachments	Used to operate internal engineering, project, safety, inspection, reporting, and administrative workflows and to maintain related records.
Push Notification Data	Firebase Cloud Messaging registration token associated with the App installation or device	Used only to route operational push notifications, such as assignment updates, workflow alerts, issue notifications, safety notices, or weather-related operational advisories. The token is not used for advertising or behavioural analytics.
Security and Technical Records	Login time, authentication status, session records, request records, error information generated by Company systems, and security audit logs	Used to protect accounts and systems, investigate operational or security incidents, maintain service reliability, and demonstrate accountability. The App does not use Firebase Analytics or Firebase Crashlytics.

The App does not collect precise real-time GPS location for continuous location tracking.

Users should capture or upload only authorized work-related information and should avoid including unrelated personal, confidential, or third-party information unless it is necessary for the relevant Company workflow.

2. How We Use Personal Data

We use personal data only for internal operational, safety, security, engineering, project-management, and administrative purposes, including to:

• authenticate authorized personnel and maintain organizational user accounts;
• assign and enforce project-, role-, or site-specific access rights;
• receive, process, review, approve, and retain work-related submissions;
• support inspections, issue reporting, safety processes, work-data scanning, and operational record-keeping;
• deliver operational push notifications through Firebase Cloud Messaging;
• protect the App, Company systems, users, sites, and operational records;
• investigate errors, suspected misuse, unauthorized access, or security incidents;
• comply with legal, regulatory, contractual, audit, safety, and engineering record-keeping obligations; and
• administer account provisioning, reassignment, suspension, deactivation, and offboarding.

We do not use personal data collected through the App for third-party advertising or marketing. We do not sell or rent personal data.

3. Camera Permission

The App uses the device camera only for user-initiated work functions, including scanning or capturing work-related data and uploading supporting images or documents. The operating system may ask the user to grant camera permission when the function is first used.

The App does not activate the camera continuously or independently in the background. Captured content is submitted only when the user performs the relevant capture, scan, save, or upload action.

4. Push Notifications and Firebase Cloud Messaging

The App uses Google Firebase Cloud Messaging (“FCM”) to deliver operational push notifications. For this purpose, the App obtains an FCM registration token associated with the App installation or device and transmits the token to the Company’s backend system.

FCM is used for notification delivery only. The App does not use Firebase Analytics or Firebase Crashlytics. We do not use the FCM token to create advertising profiles, conduct behavioural advertising, or track users across third-party apps or websites.

Users may manage notification permission through their device settings. Disabling notification permission may prevent the device from receiving operational alerts sent by the App.

5. Service Providers, Systems, and Data Disclosure

Personal data may be processed by the following service providers or systems only to the extent necessary to operate and support the App:

Provider or System	Role and Data Involved
Microsoft Entra ID	Organizational identity authentication and single sign-on. Microsoft may process the account identifier and authentication information required to verify the user’s organizational identity.
Google Firebase Cloud Messaging	Delivery of operational push notifications using an FCM registration token and notification-routing information.
Company-operated backend infrastructure cmpapi.kinwing.com.hk	Authentication integration, access control, storage and processing of work submissions, scanned or captured work data, operational records, attachments, notification tokens, and security records.

We may also disclose personal data where reasonably necessary to:

• authorized Company personnel, project managers, site administrators, auditors, or contractors who require access for legitimate work purposes;
• comply with applicable law, court orders, regulatory requirements, contractual obligations, or lawful requests;
• protect the safety, rights, property, systems, or legitimate interests of the Company, its personnel, clients, contractors, or other persons; or
• investigate suspected fraud, misuse, security incidents, or unauthorized access.

Service providers that process personal data on our behalf are expected to process it only for the relevant services, apply appropriate technical and organizational safeguards, and protect it in a manner consistent with this Privacy Policy and applicable requirements.

6. Cross-Border Processing

Microsoft, Google, or other supporting infrastructure may process limited personal data or technical information on systems located outside Hong Kong. Where cross-border processing occurs, we apply reasonable technical, contractual, and organizational safeguards appropriate to the nature of the data and the service involved.

7. Data Retention

We retain personal data only for as long as reasonably necessary for the purpose for which it was collected or a directly related purpose, subject to legal, regulatory, contractual, safety, audit, and engineering record-keeping requirements.

• Account and identity data: normally retained while the user remains employed, engaged, assigned, or otherwise authorized to access the App, and for any additional period required for offboarding, security, audit, dispute handling, or legal compliance.
• FCM registration tokens: retained while required to send operational notifications and removed, replaced, or invalidated when the token is no longer necessary, the installation is replaced, or the account is deactivated.
• Work submissions and attachments: retained according to the applicable project, contract, engineering, inspection, safety, audit, and legal record-keeping requirements.
• Security and technical records: retained for periods reasonably necessary to maintain security, investigate incidents, resolve technical issues, and satisfy audit or legal requirements.

Where a record must be retained after account deactivation, we will limit access and may delete, redact, or anonymize personal identifiers where reasonably practicable and consistent with the purpose of retention.

8. Data Security

We implement reasonable technical and organizational safeguards designed to protect personal data against unauthorized or accidental access, processing, loss, alteration, disclosure, or destruction. These safeguards include, where applicable:

• encrypted network communication using HTTPS/TLS;
• organizational identity authentication and role-based access control;
• restricted administrative access;
• security logging, monitoring, and account lifecycle controls;
• protected backend systems and controlled data access; and
• secure operating-system storage for locally stored authentication tokens, where applicable.

No electronic transmission, device, or storage system can be guaranteed to be completely secure. Users must protect their organizational credentials, device access, and authentication information and promptly report suspected loss, misuse, or unauthorized access to the IT Department.

9. Account Lifecycle and Internal Administration

• Account creation: Accounts are created, assigned, or approved by the Company’s IT Department or authorized site administrators. The App does not provide public self-registration.
• Access changes: Access rights may be modified when a user changes role, project, site, department, or contractual assignment.
• Suspension or deactivation: Access may be suspended or deactivated for offboarding, reassignment, inactivity, security, policy, legal, or operational reasons.
• Organizational identity: Deactivation of an App profile may be coordinated with the user’s Microsoft Entra ID or other organizational account administration.

10. Account and Data Deletion Requests

Because CKW SPOT accounts are provisioned and controlled internally, users cannot create or delete an organizational account through public self-service registration. Authorized users may nevertheless request review, deactivation, deletion, or anonymization of personal data associated with their CKW SPOT profile.

How to submit a request

Send an email to itteam@kinwing.com.hk with the subject “CKW SPOT Account and Data Deletion Request”. The request should include:

• the user’s full name;
• work email address or staff/contractor code;
• the relevant project or site, where applicable; and
• a description of the requested action.

Verification and processing

We may verify the requester’s identity and authority before processing the request. Following successful verification, we will revoke or deactivate active CKW SPOT access and delete or anonymize personal data that is no longer required. We aim to complete the applicable action within 30 days after verification and will inform the requester if additional time or information is reasonably required.

Information that may need to be retained

Deletion does not require us to erase records that must remain available for legal, regulatory, contractual, safety, audit, security, dispute-resolution, or engineering record-keeping purposes. This may include inspection records, issue reports, safety submissions, project records, approvals, audit trails, and related attachments. Where retention is required, access will be limited and personal identifiers may be deleted, redacted, or anonymized where reasonably practicable.

Temporary suspension or account deactivation is not represented as deletion of all associated records. We will explain the outcome of the request and identify any categories of information that must continue to be retained.

11. Access and Correction Rights

Subject to the PDPO, an individual may request access to personal data held by the Company and request correction of inaccurate personal data.

Requests should be submitted in writing to itteam@kinwing.com.hk. We may require sufficient information to verify the requester’s identity, locate the relevant records, and understand the scope of the request.

We will handle a valid data access request within 40 calendar days after receipt, subject to applicable provisions, permitted exceptions, identity verification, and any lawful fee that may apply. Correction requests will be handled in accordance with the applicable PDPO requirements.

12. Children’s Privacy

The App is intended only for authorized employees, site personnel, and contractors of the Company. It is not directed to children or members of the general public, and we do not knowingly provide App accounts to individuals under 18 years of age.

13. Changes to This Privacy Policy

We may update this Privacy Policy to reflect changes in the App, operational practices, service providers, security measures, legal requirements, or regulatory guidance. The revised version will be published on this page with an updated “Last updated” date.

Material changes affecting the handling of personal data may also be communicated through the App, organizational notices, email, or other appropriate Company channels.

14. Contact Us

For questions, concerns, access or correction requests, or account and data deletion requests relating to CKW SPOT, please contact:

Kin Wing Engineering Company Limited
IT Department
Block A&B, 8/F., Hong Kong Spinners Industrial Building, Phase VI
481–483 Castle Peak Road, Kowloon, Hong Kong
Email: itteam@kinwing.com.hk
Website: https://cmp.kinwing.com.hk

This Privacy Policy applies to the CKW SPOT mobile application and the related Company-operated services described above.