This policy specifically addresses the Company’s obligations in respect of the data privacy laws of the Hong Kong Special Administrative Region (“Hong Kong”). Where the Company’s operations are subject to privacy legislation other than that of Hong Kong, then this policy shall be applied so far as applicable and consistent with such local legislation.
Collection of Personal Data
When you come to our Site, for the purpose of carrying out the Company’s businesses, including sale, provision, administration of the membership services and related products and services, you may be requested to provide us with personal data including without limitation name, telephone number, email address and corresponding address.
The Site may also collect data relating to your online session, the types of data may include but are not limited to the browser type and version; operating system; the IP address and /or domain name; and URLs.
Use of Personal Data
When you provide personal data to us, you are deemed to have given us authorization to collect, retain and use your personal data as follows:
- verifying your identity; provision of goods and services to you;
- providing you with our promotional materials, marketing and advertising of any goods and/or services to you by the Company, agents, contractors and third party upon your consent in accordance with the requirement of the Ordinance;
- business planning and improving goods and/or services to you by the Company;
- processing of any benefits or membership application in connection with the supply of goods and services to you;
- providing you with customer services, more personalized experience in respect of our Site, mobile applications, products, services and/or your membership or user account and responding to your queries, feedback, complaints or claims;
- proccessing of any payment instructions or credit facilities in relation to supply of goods and services to you;
- enabling the daily operation of your membership account with the Company;
- prevention of crime;
- disclosure as required by law;
- handling of complaints and enquiries of the customers; and
- any other purposes as may be agreed between you and the Company apart from this Policy.
Retention of Personal Data
The Company will destroy any personal data it may hold in accordance with its internal policy.
i. Personal data will only be retained for as long as is necessary to fulfill the purposes for which it was collected, unless retention is required to satisfy any applicable statutory or contractual obligations; and
ii. Personal data is erased from the Company’s electronic and other filing systems in accordance with the schedules based on the company’s internal procedures.
Disclosure of Personal Data
All personal data held by the Company will be kept confidential and will not be disclosed or transferred to any other party but the Company may, where such disclosure is necessary to satisfy the purpose, or a directly related purpose, for which the data was collected, provide such information to the following parties:
i. any subsidiary, associated company, affiliated company or company that is affiliated with, or controlled by, or under common control with the Company;
ii. third party services providers under a duty of confidentiality to the Company engaged to enable the Company to carry out any of the purposes your personal data was collected for;
iii. any other person or company who is under a duty of confidentiality to the Company and has undertaken to keep such information confidential provided such person or company has a legitimate right to such information;
iv. Government and regulatory authorities and law enforcement agencies and other organisations as required or authorized by law.
Transfer of Personal Data Outside Hong Kong
It may be necessary for the Company to transfer certain personal data to places outside the Hong Kong in order to carry out the purposes or directly related purposes, for which the personal data were collected.
Access and Correction of Personal Data
You have the right to request access to personal data the Company holds about you. You have a further right to request correction of your personal data.
You may at any time send requests for access or correction of your personal data held by the Company to firstname.lastname@example.org。
Handling Personal Information About Recruitment and Employment
During the recruitment process, job applicants may be required to provide sufficient personal data so that the Company may assess the applicant’s suitability for the position of the Company and determine the preliminary remuneration and benefit packages. Sometimes the applicant’s credentials and/or experience is needed to be verified. The personal data will include:
i. The applicant’s name, contact details including address and telephone number;
ii. Employment history and relevant experience; and
iii. Education and training.
The personal data so provided may be transferred to our subsidiaries and associated companies (“Group Companies”) which are involved in the assessment of the applicant’s suitability for the position applied for and/or other positions, which may be, or may become, available within the Group Companies.
The Company shall retain the personal data of unsuccessful applicants for future recruitment purposes for a period of two years from the day on which the application is received.
The personal data of successful applicants shall be retained for the duration of their employment and as required by law by the Company as described below under the sub-heading “Employment”.
Employment including Post-Employment:
In the course of employment by the Company, personal data of employees will be collected and used for various human resources management purposes. These purposes include, but are not limited to, provision of benefits, compensation and payroll, facilitating performance appraisals, promotion and career development activities, making tax returns, administering staffing, training, insurance, welfare, provident fund administration, security/identification purposes and other purposes so as to comply with the legal requirements. Such personal data will be transferred to those internal departments, Group Companies, and/or to other third parties such as the insurers, bankers, medical practitioners as is necessary for the purposes.
The Company retains certain personal data of employees when they cease to be employed by us. Such data are required for any residual employment-related activities in relation to a former employee including, but not limited to the provision of job references, processing application for re-employment matters, retirement benefits and allowing us to fulfil contractual or statutory obligations.