1. Data Controller
JG PERFORMANCE SYNDICATE LTD
19H Maxgrand Plaza, No. 3 Tai Yau St, San Po Kong
Hong Kong
Email: contact@performance-syndicate.com
Phone: +852 5 944 7390
This website is intended for users worldwide, including the European Union. Although our company is based outside the EU, we comply with the requirements of the EU General Data Protection Regulation (GDPR) pursuant to Art. 3 (2) GDPR.
2. Data Protection Officer
Currently, no external Data Protection Officer has been appointed. Responsibility for compliance with data protection requirements lies with the company itself.
3. Scope of Data Processing
We process personal data only to the extent necessary for providing our content, services, and features. We adhere to principles of data minimization, purpose limitation, and confidentiality.
4. Categories of Data Processed
We may process the following categories of personal data:
Master data (name, address, date of birth)
Contact details (email, phone number)
Payment details (credit cards, bank accounts, payment status)
Communication data (e.g. IP address, browser type, device information)
Content data (texts, photos, uploads via forms)
Usage data (page views, time spent, click behavior)
Meta/connection data (device information, log files)
5. Legal Bases
Depending on the purpose, processing is based on the following legal grounds:
Art. 6 (1) lit. a – Consent
Art. 6 (1) lit. b – Contract performance or pre-contractual measures
Art. 6 (1) lit. c – Legal obligation
Art. 6 (1) lit. f – Legitimate interest
6. Recipients and Processors
Data may be processed by external service providers (processors), such as:
Web hosting providers (e.g. AWS, IONOS)
IT service providers
Payment providers (Stripe, PayPal)
Newsletter services (Mailchimp)
Analytics and advertising providers (Google, Meta)
All processors are bound by Data Processing Agreements (DPAs) in accordance with Art. 28 GDPR.
7. Data Transfers to Third Countries
Since many of our service providers are located in third countries (e.g. USA), data transfers only occur if:
An EU adequacy decision exists, or
We have concluded Standard Contractual Clauses (SCCs), or
You have expressly consented (Art. 49 (1) lit. a GDPR).
8. IT Security
We implement technical and organizational measures in accordance with Art. 32 GDPR to protect your data against loss, manipulation, and unauthorized access. These include:
SSL encryption
Firewall/DDoS protection
Access controls
Data backups
Regular updates
Secure password policies
Access restrictions for service providers
9. Cookies and Consent Management
Our website uses a cookie consent tool to manage your preferences. The legal basis for non-essential cookies is your consent (Art. 6 (1) lit. a GDPR).
You may withdraw or adjust your consent at any time.
10. Analytics and Marketing Tools
We use, among others, the following services:
Google Analytics
User behavior analysis, IP anonymization, processing in the USA, SCCs in place.
Opt-out link: Disable Google Analytics
Facebook/Meta Pixel
Advertising effectiveness measurement, remarketing, SCCs in place.
Mailchimp Newsletter
Double opt-in procedure, unsubscribe at any time.
Data transfer to the USA based on SCCs.
11. Payment Processing
Payments are handled via third-party providers:
Stripe (Stripe Inc., USA)
PayPal (PayPal Inc., USA)
The providers’ own privacy policies apply. Data transfers are based on SCCs.
12. Applications
If you apply with us, we process your application documents solely for recruitment purposes. Data will be deleted no later than 6 months after the procedure ends unless legal retention obligations apply.
13. No Automated Decision-Making
We do not use automated decision-making or profiling within the meaning of Art. 22 GDPR.
14. Protection of Minors
Our website is not directed at individuals under 16 years of age. We do not knowingly process children’s data. Parents/guardians may contact us if they suspect personal data of a child has been processed.
15. Data Retention
We store personal data only as long as necessary to fulfill the stated purposes or as required by law (e.g. tax retention obligations of up to 10 years).
16. Your Rights
You have the right to:
Access (Art. 15 GDPR)
Rectification (Art. 16 GDPR)
Erasure ("right to be forgotten", Art. 17 GDPR)
Restriction of processing (Art. 18 GDPR)
Data portability (Art. 20 GDPR)
Objection to processing (Art. 21 GDPR)
Withdrawal of consent (Art. 7 (3) GDPR)
To exercise your rights, please contact us:
Email: contact@performance-syndicate.com
17. Server Log Files
Every access to our website automatically generates log files by our hosting provider, including:
Browser type and version
Operating system used
Referrer URL
Hostname of accessing computer
Time of server request
IP address
These logs serve security and system stability (e.g. attack detection) and are stored based on Art. 6 (1) lit. f GDPR (legitimate interest).
18. Social Media Accounts
We maintain online presences on social networks (e.g. Instagram, Facebook, TikTok). When you visit our profiles, the privacy policies of the respective operators apply.
Data processing may be carried out by the platforms themselves and, in some cases, jointly with us (Art. 26 GDPR).
Operators & privacy policies:
Facebook & Instagram (Meta Platforms Ireland Ltd.)
Privacy Policy: https://www.facebook.com/about/privacy/
TikTok (TikTok Technology Limited, Ireland)
Privacy Policy: https://www.tiktok.com/legal/privacy-policy
Your interactions (e.g. comments, likes, messages) may be processed by us when you engage with us.
19. External Links
Our website may contain links to external sites. We are not responsible for their content or privacy practices. Please review their privacy policies independently.
20. Hosting & Content Delivery Networks (CDN)
Our website may use CDNs (e.g. Cloudflare, Amazon CloudFront) to improve performance and stability. This may involve transmission of your IP address to the CDN provider. The use is based on our legitimate interest in secure and efficient delivery (Art. 6 (1) lit. f GDPR).
21. Third-Party Content (e.g. YouTube, Google Maps)
We may integrate third-party content (e.g. videos, maps). This requires third parties to process your IP address and may involve cookies or tracking. The legal basis is your consent (Art. 6 (1) lit. a GDPR).
Examples:
YouTube (Google Ireland Limited) – video content
Google Maps – map display
reCAPTCHA – spam protection
22. Right to Lodge a Complaint
You have the right to lodge a complaint with a supervisory authority. A list can be found here:
https://www.bfdi.bund.de/DE/Service/Anschriften/Laender/Laender-node.html
23. Changes to this Privacy Policy
We reserve the right to amend this Privacy Policy at any time. The current version will always be available on our website.