Privacy
How this website and the district communication desk of L Eclat Communication Limited handle personal information.
This Privacy Policy explains how personal information is collected, used, stored and protected when you visit this website, send an enquiry, ask for a district route proposal, or otherwise deal with the district communication desk operated by Vast District under L Eclat Communication Limited. Vast District is the developer name attached to this website, and the studio work described across these pages is delivered by the team that operates the Prince Edward desk. The policy is written in plain English because a privacy notice that cannot be read is not a privacy notice at all. Please take a few minutes to understand what we do and why.
We are a small studio. We do not run advertising networks, we do not build behavioural profiles of visitors, and we do not sell personal information to anyone. Most of the information we hold arrives because somebody chose to write to us, call us, or ask us to plan a printed round for a specific set of streets. That information is used to answer the enquiry, deliver the work and keep an accurate business record. Everything else in this policy is detail around that simple position.
The company responsible for the processing described here is L Eclat Communication Limited, Rm 702 7/F Cheung Fung Comm Bldg, 21-25 Cheung Sha Wan Rd, Prince Edward, Hong Kong - 999077, Hong Kong (HK). Where this policy refers to the Company, it means that entity. Where it refers to the desk, it means the working team at that address.
By using this website you acknowledge that you have read this policy. If you do not agree with it, please do not submit an enquiry through the contact page and instead contact us by telephone so that we can explain the options available to you.
This policy applies to the website published at the address shown in the site footer, to all pages within that site, and to enquiries and correspondence that begin through it. It also applies to personal information gathered during the planning and delivery of a district round, including the contact details of client staff, host shopkeepers, delivery route contacts and the people who appear in shop interview features.
This policy does not apply to third party websites that we link to, to the internal systems of our clients, or to information that a client collects from its own customers. Each of those parties is responsible for its own notices. Where we act as a processor for a client, the client notice and the contract between us govern that work, and this policy describes only the part of the processing carried out under our own responsibility.
L Eclat Communication Limited is the controller of personal information collected through this website and through direct enquiries made to the desk. The Company decides why information is collected, how long it is kept and who is allowed to see it.
The Company can be reached by post at Rm 702 7/F Cheung Fung Comm Bldg, 21-25 Cheung Sha Wan Rd, Prince Edward, Hong Kong - 999077, Hong Kong (HK), by email at contact@vastdistrict.autos, or by telephone at +18028312666. Enquiries about privacy are handled by the person responsible for desk operations, who also maintains the internal record of processing described in section twenty one.
The information we collect falls into a small number of practical categories. We try to collect only what is needed for the task at hand, and we avoid asking for details that make no difference to the answer you receive.
When you use the contact form or write to the desk, we receive the name you choose to give, the email address you reply from, the subject line you write and the contents of your message. If you call, we may note your telephone number and a short summary of the conversation. If you visit the desk in person, we may record your name and the organisation you represent for the purpose of arranging follow up.
Planning a district round involves recording host frontages, shop names, opening hours and the name of the person who agreed to display a bulletin. For interview features we record the details a host chooses to share about the shop, and we seek confirmation of any quotation or description before print. This information is business information about the shop, and only the parts that identify an individual are treated as personal information.
Our web server receives technical information whenever a page is requested, including the internet protocol address of the device, the browser type, the operating system, the page requested, the referring page and the time of the request. This information is used for security, troubleshooting and aggregate measurement. It is not used to identify individual visitors.
We do not ask for identity document numbers, financial account details, health records or information about political or religious beliefs. If such information arrives unsolicited in a message, we delete it as soon as we notice it unless there is a clear reason to keep it for the specific enquiry concerned.
Most information comes directly from you. You type it into the contact form, you send it in an email, you speak it on the telephone, or you hand over a business card during a district walk. We also receive information indirectly in a few limited ways.
Our web server logs technical details automatically. A client may pass on the name and email address of a colleague who will coordinate a campaign, and we treat that introduction as the colleague having been informed by the client. A shopkeeper may tell us about a neighbouring business that would like to take part in a bulletin round, and in that case we contact the neighbour using the details provided and confirm their consent to be included before any printed material is produced.
We do not buy contact lists, we do not scrape directories for email addresses and we do not acquire information from data brokers. If we cannot reach you through a route you already opened, we do not look for another one.
We use personal information to answer enquiries and to deliver the communication rounds described on the services page. In practical terms this means preparing route proposals, confirming placement permissions, producing print specifications, coordinating paste days, issuing inspection reports and maintaining an accurate record of the work performed.
We also use information to keep the website working, to protect it from abuse, to understand in aggregate how many people visit and which pages are read, and to improve the clarity of the content. Occasionally we use contact details to send a short note about a service change or a new round window, but only where the recipient has asked to receive such notes or where the recipient is an existing client and the note relates directly to work already underway.
We may use information to meet accounting, tax and record keeping obligations, to respond to a lawful request from a public authority, or to establish and defend legal claims. These uses are narrow and are always tied to a specific obligation rather than to general curiosity.
Where the law requires us to identify a lawful basis, we rely on the following. For answering an enquiry or delivering a campaign we rely on the performance of a contract or on steps taken at your request before a contract is formed. For record keeping, security, accounting and legal compliance we rely on our legitimate interests and on legal obligation. For any optional note about future rounds we rely on consent, which you may withdraw at any time.
When we rely on legitimate interests we consider whether the processing is necessary, whether it is proportionate and whether it would reasonably be expected by the person concerned. A small studio answering the phone and keeping a project file passes that test. Building a profile of a visitor for advertising would not, which is precisely why we do not do it.
We look at aggregate figures rather than individual journeys. The server records page requests and errors so that we can tell whether the site is available and whether a page is loading slowly. Those records are reviewed in summary form and are used to fix problems, not to evaluate individuals.
If we use an external measurement service in the future, we will configure it to avoid advertising features, we will not enable cross site tracking and we will disclose the provider in this section. You will always be able to read this site without accepting measurement.
District rounds are printed and placed on behalf of clients. That work involves information about shopkeepers and hosts, but it is not marketing to those individuals. A host agrees to display a bulletin, receives a copy for their own use and may ask to be removed from the next round at any time. Removing a host from a round is straightforward and does not require a reason.
Where we send a note about our own services, we keep the note short, we include a clear way to stop receiving it and we honour a stop request immediately. We do not share contact details with other organisations for their own marketing, and we do not add an enquiry address to a list without a clear statement at the point of collection.
We share personal information only when there is a practical reason and only to the extent required. The main recipients are the service providers described in the next section, professional advisers who need a specific record to answer a specific question, and public authorities where the law compels disclosure.
We do not sell personal information. We do not rent contact lists. We do not share enquiry details with advertising partners, data brokers or any party whose purpose is unrelated to the work you asked us to do. If a client asks us to introduce a host shopkeeper to a third party, we ask the shopkeeper first and we respect a refusal without further discussion.
If the business is reorganised, merged or transferred, information may move with the operating assets. In that event the receiving party must honour the commitments in this policy, and we will make reasonable efforts to notify affected individuals before records are transferred where the law allows.
Like any small business we rely on a few suppliers. Our website hosting provider stores the files that make up this site and logs requests. Our email provider carries messages between the desk and the people who write to us. Our print suppliers receive artwork and delivery lists for a specific run and are told to destroy the files once the run is complete. Our accountant sees invoices and payment records, not the contents of client correspondence.
Each supplier is selected with care and is required to protect the information it handles, to use it only for the service it provides and to return or delete it when the engagement ends. We review these arrangements when a contract is renewed and whenever a supplier changes the way its service works.
The desk operates from Hong Kong. Some of our suppliers may store data in another jurisdiction, which means information can leave Hong Kong in the course of ordinary hosting or email delivery. Where that happens we take reasonable steps to ensure the receiving party is bound by protections consistent with this policy and with applicable law.
If you would like to know where a particular category of information is stored before you send it, ask us and we will explain rather than guess. For most enquiries the answer is simple: the message sits in a mailbox and a project file, and both are access controlled.
We keep information only as long as it serves the purpose for which it was collected. A general enquiry that does not lead to work is usually deleted within twenty four months of the last exchange. Project records, including route maps, print samples and inspection reports, are kept for seven years after the end of the campaign so that we can answer a question about what was placed on the street and when.
Accounting and tax records are kept for the period required by law. Interview drafts and photographs are kept while the feature is in print and for a short period afterwards in case a correction is needed, then archived or deleted according to the wishes of the host. Server logs are rotated on a short cycle and are not retained indefinitely.
When a retention period ends we delete the information or, where deletion is impractical because the record sits inside an archive, we restrict access to it and mark it for suppression so that it is not used for any active purpose.
Access to desk records is limited to the people who need it for their work. Accounts are protected by strong passwords and by multi factor authentication where the service supports it. Files are stored on managed services rather than on a shared drive, and portable copies are avoided except when a print run requires a temporary file on a controlled device.
We keep the number of copies of any record low, we review access when a person leaves the team and we test the restore of our backups at intervals. The website is served over an encrypted connection. Physical papers, including signed route sheets and host agreements, are kept in a locked cabinet at the desk and are separated into active and archive boxes.
No system is perfectly secure. If a breach occurs that is likely to result in a risk to the rights of individuals, we will notify the affected people and the relevant authority without undue delay, and we will describe what happened in plain language rather than in a reassuring summary.
Subject to the law that applies to you, you may ask for a copy of the personal information we hold about you, ask us to correct anything that is inaccurate, ask us to delete information that is no longer needed, ask us to restrict how information is used, object to a particular use, and ask for a portable copy of information you provided to us.
Where we rely on consent you may withdraw it at any time, and withdrawal does not affect the lawfulness of processing carried out before the withdrawal. You may also complain to a supervisory authority. We would prefer that you speak to us first so that we can put things right quickly, but the right to complain is yours and is not conditional on contacting us.
To exercise a right, write to contact@vastdistrict.autos with enough detail to identify the record you mean. We may ask for proof of identity where the request concerns sensitive information or where we are not certain who is writing.
We aim to answer an access request within thirty days. If the request is complex, or if we need to retrieve material from an archive, we will tell you within that period when a full answer can be expected and why more time is needed. There is normally no charge for a request, although where requests are manifestly unfounded or repetitive we may refuse them and explain the reason.
Where we cannot comply with a request, for example because the information concerns another person or because a legal obligation requires retention, we will explain the limitation and set out any remedy available to you. We will not use a limitation as a way of avoiding a legitimate request.
This website is intended for business and professional readers. We do not knowingly collect personal information from children under the age of sixteen. District rounds are planned for shops, offices and residential entrances and are not directed at children.
If a parent or guardian believes that a child has sent personal information to the desk, they should contact us and we will delete the information promptly. If a shop interview feature is proposed that would involve a young person, we will ask the host to arrange consent from a parent or guardian before any sitting takes place.
Pages on this site may link to the websites of clients, suppliers or public bodies. Those sites are outside our control and have their own privacy notices. A link is not an endorsement of the way another organisation handles information, and you should read the notice on any site before sending personal details to it.
We check outgoing links when a page is published, but we do not monitor third party content continuously. If you find a link that has changed its destination or now leads to material that seems out of keeping with this site, tell us and we will review it.
We review this policy at least once a year and whenever we change a supplier, introduce a new feature or alter the way the desk works. When a change is material we will update the date at the top of the page and, where we hold an email address for you and the change affects your information, we will send a short note describing what has changed.
Earlier versions are kept in the desk archive so that we can explain how the policy read at the time a particular piece of information was collected. If you need to see an earlier version, ask us and we will supply it.
Questions about this policy, requests to exercise a right, and complaints about the way information has been handled should be sent to L Eclat Communication Limited at Rm 702 7/F Cheung Fung Comm Bldg, 21-25 Cheung Sha Wan Rd, Prince Edward, Hong Kong - 999077, Hong Kong (HK), by email to contact@vastdistrict.autos, or by telephone at +18028312666 during business hours.
The desk keeps a written record of privacy enquiries and the action taken on each. That record is reviewed when this policy is updated, because the questions people actually ask are the best guide to what a policy should explain. If something here is unclear, tell us and we will rewrite it rather than defend it.
This policy applies to the website and desk operations of L Eclat Communication Limited and is provided for information. It does not create rights beyond those conferred by applicable law.