About this policy
This Privacy Policy explains how Morning Sunlight Asia Limited collects, uses, retains, discloses and protects personal data and project information when visitors use the website, submit procurement requirements, send drawings or communicate with us about a project.
It applies to this website, the project submission form, email and communications directly related to project assessment. It does not replace a signed non-disclosure agreement, service contract, procurement contract or other written agreement.
Data controller
The data controller is Morning Sunlight Asia Limited.
Privacy Contact: soren@mornsunasia.com.
Contact address: Room D07, 8/F, Kai Tak Factory Building Phase II, 99 King Fuk Street, San Po Kong, Hong Kong.
Information we may collect
We may collect your name, company name, job title, business email, telephone number, country or region, the organisation you represent and information about its business.
Project information may include product and part details, drawings, BOMs, sample information, material and process requirements, quantities, applications, destinations, quality standards, certification requirements, delivery timing, buyer-nominated supplier details and other project instructions.
During communications, we may retain emails, meeting notes, quotation questions, technical clarifications, project decisions, inspection information and issue-resolution records.
The website and hosting services may automatically generate IP addresses, browser and device information, access times, pages visited, error logs and security logs. This website currently uses browser local storage to remember language selection and does not use advertising tracking or behavioural profiling.
Required and optional information
Information marked with an asterisk in the project form is required for an initial project assessment. Without it, we may be unable to assess project fit, contact you or recommend a next step.
Quantity, material, process, certification, destination, end use and attachments are optional unless marked otherwise, but insufficient information may affect the accuracy of our assessment.
How we use information
We may use information to respond to enquiries; verify contact and business identity; assess business, technical and compliance fit; understand drawing, BOM, material, process, quality and delivery requirements; clarify information gaps, scope, quotation basis and working arrangements; and keep project records.
After authorisation or within an agreed scope, we may also use it to assess and contact suppliers, carry out contracted procurement, production, quality and delivery-readiness work, resolve issues, maintain information security, prevent fraud, meet accounting, tax, export-control and other legal obligations, and establish, exercise or defend legal rights.
We do not use drawings, BOMs or project information for marketing unrelated to the project, and we do not sell personal data.
Legal bases for processing
Where applicable law requires a legal basis to be identified, processing may be based on your consent, steps taken at your request before entering a contract, performance of a contract, compliance with a legal obligation, or legitimate interests necessary for project assessment, information security and business operations.
You may withdraw consent-based processing. Withdrawal does not affect processing already carried out lawfully or information that we must retain under law or contract.
Drawings, BOMs and confidential information
Drawings, BOMs, specifications and sample information may contain trade secrets. You may begin with redacted or non-confidential information and request a non-disclosure agreement before detailed files are exchanged.
Submitting a file through the website does not automatically create a separate confidentiality agreement. Formal confidentiality obligations, permitted use, authorised recipients, retention and return or destruction arrangements are governed by a signed non-disclosure agreement or project contract.
Information you should not submit through the website
Unless we specifically request it and a secure transfer method has been agreed, do not submit identity documents, bank account or payment-card details, passwords, health information, sensitive personal data, material subject to strict third-party restrictions or trade secrets that you are not authorised to disclose.
For controlled items, provide only a general description until the required licensing and confidentiality arrangements have been confirmed. Do not send complete restricted technical information before that point.
Recipients of information
Where necessary for an agreed purpose, information may be provided to authorised Morning Sunlight Asia personnel and the China-side operating team; candidate suppliers, factories, testing organisations and professional service providers approved by the client or permitted by the project scope; website hosting, form-processing, email, file-storage, cybersecurity and information-technology providers; accountants, lawyers, insurers, banks and other professional advisers; government, customs, regulatory or law-enforcement authorities entitled to receive it; and parties bound by confidentiality in a corporate reorganisation, financing, merger or asset transfer.
We disclose only the information reasonably necessary for the specific work.
China-side processing and international transfers
Morning Sunlight Asia Limited is a Hong Kong company, but project work may require information to be handled by the China-side operating team. Website hosting, email or file-storage providers may also process information in Hong Kong, mainland China or other jurisdictions.
Depending on the information and service arrangement, we use reasonable measures such as access controls, confidentiality duties and contractual protections for transferred information. Specific providers and processing locations will be reviewed when production arrangements are confirmed.
Direct marketing
Submitting a project requirement does not automatically enrol you in unrelated marketing.
If we send marketing communications in the future, we will obtain any consent required by applicable law and provide a way to unsubscribe. You may ask us to stop marketing communications at soren@mornsunasia.com.
Retention
Enquiry information that does not lead to an engagement is normally retained for no more than 12 months after the last substantive communication, unless ongoing negotiations, a dispute, a security incident or another lawful reason requires longer retention.
For accepted projects, contracts, transaction, payment, invoice and necessary project records may be retained for at least seven years where required for Hong Kong business records.
Drawings and technical files are reviewed periodically and deleted, returned or anonymised when no longer needed for project assessment or contractual purposes and when no legal obligation or dispute requires retention.
Security
We use administrative and technical measures appropriate to the risk, which may include restricted access, authentication, permission management, protection during transfer, backups, logging and reasonable review of service providers.
Internet transmission and electronic storage cannot be guaranteed to be completely secure. Before submitting particularly sensitive drawings or large files, confirm the confidentiality agreement and secure file-exchange method with us.
Your rights
Subject to applicable law, you may have rights to request access to, correction or deletion of personal data, restriction of or objection to certain processing, withdrawal of consent, or a copy of your data.
We may need to verify your identity and authority. We may be unable to delete all information immediately where it is required to perform a contract, comply with law, handle a dispute or protect the rights of others.
Send requests to soren@mornsunasia.com with the subject line ‘Personal Data Request’ so that we can identify the purpose of your message.
Minors
This website is intended for businesses and professional procurement personnel, not minors. We do not knowingly collect personal data from minors.
Third-party websites
This website may link to government bodies, industry organisations, technical standards or other third-party websites. Those websites have their own privacy policies, and we do not control how they process information.
Changes to this policy
We may update this policy when website functions, service arrangements, providers or legal requirements change.
Material changes will be stated clearly on the website and, where applicable, we will seek consent again.
Contact
Company: Morning Sunlight Asia Limited.
Email: soren@mornsunasia.com.
Address: Room D07, 8/F, Kai Tak Factory Building Phase II, 99 King Fuk Street, San Po Kong, Hong Kong.