Last modified on April 2023
Definition. The words of which the initial letter is capitalised have meanings defined under the following definition. They shall have the same meaning regardless of whether they appear in singular or in plural.
“Personal Data”. Any information relating to an identified or identifiable natural person; an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
“Processing”. Any operation or set of operations which is performed on Personal Data or on sets of Personal Data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
“Restriction of Processing”. The marking of stored Personal Data with the aim of limiting their Processing in the future.
Personal Data We Collected. We collect Personal Data directly from you in a variety of ways.
- Visit Our Website. When you visit our websites, we will record each of your visits and automatically collect the following information:
❖ technical information, including the IP address used to connect your computer to the Internet, browser type and version, geo-location, time zone setting, browser plug-in types and versions, device types, operating system, time and date of consent and platform; and
❖ information about your visit, including the full Uniform Resource Locators, clickstream to, through and from our websites (including date and time), products you viewed, searched for, filtered, the hyperlinks you have clicked, the websites you visited before arriving at our websites, page viewed, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs) and methods used to browse the websites.
- Make Order with Us. When you make an order with us, we will collect Personal Data such as:
❖ your personal details, including your name, company name, address, email address and phone number; and
❖ your billing details, including your billing address and delivery address.
- Apply for Job with Us. When you apply for a job with us (through email, by post or submit an application through our website), you are asked to provide Personal Data such as your name, telephone number, email address and correspondence address. We may also collect your resume, transcripts and reference letters, which may contain your Personal Data such as academic record, employment history and professional qualification. When you provide Personal Data of your referees to us, such as their names, company names, titles and contact details, you should have obtained their consent to act as your referees and provide such data to us.
Should you be offered a job with us, you are asked to complete a form for employment which may require you to provide other Personal Data such as your Hong Kong identity card number/ passport number and vaccination status. Further, in the course of your employment, should an update to your Personal Data in our record be required, we may collect additional Personal Data from you.
- Make Enquiry with Us. When you make an enquiry with us, through telephone call, email or otherwise, our representative may collect your Personal Data such as your name, date of birth, telephone number, email address, correspondence address and identity proof.
Personal Data We Use. We use your Personal Data for the following purposes:
- Administer Our Website and Internal Management, including troubleshooting, data analysis, testing, research, statistical and survey purposes and controlling illegal acts.
- Process Your Order, including arranging for product delivery, updating you on the delivery progress, verifying payment status and issuing product warranty.
- Evaluate Your Job Application, including maintaining our human resources record after you are offered an employment with us,
- Assist You with Your Questions, including verifying your identity and communicating with you if follow-up is required.
Legal Bases. The legal bases for collecting and processing your information as set out in the Policy are as below:
- Consent. You have given Consent to Processing of your Personal Data for one or more specific purposes.
- Performance of a Contract. Processing is necessary for the performance of a contract with you and/ or for any pre-contractual obligation thereof.
- Legal Obligation. Processing is necessary for compliance with a legal obligation to which we are subject.
- Vital Interests. Processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in us.
- Legitimate Interests. Processing is necessary for the purposes of the legitimate interests pursued by us.
Your Rights. You have the right to
- Request Access to Your Personal Data. You shall have the right to obtain from our confirmation as to whether or not Personal Data concerning you are being processed, and, where that is the case, access to Personal Data and the following information:
❖ the purposes of Processing;
❖ the categories of Personal Data concerned;
❖ the recipients or categories of recipient to whom Personal Data have been or will be disclosed, in particular recipients in third countries or international organisations;
❖ where possible, the envisaged period for which Personal Data will be stored, or, if not possible, the criteria used to determine that period;
❖ the existence of the right to request from us rectification or erasure of Personal Data or Restriction of Processing of Personal Data concerning you or to object to such Processing;
❖ the right to lodge a complaint with us; and/ or
❖ where Personal Data are not collected from you, any available information as their source.
- Request Correction of Your Personal Data That We Hold About You. You shall have the right to obtain from us the rectification of inaccurate Personal Data concerning you. Taking into account the purposes of Processing, you shall have the right to have incomplete Personal Data completed.
- Request Erasure of Your Personal Data. You shall have the right to obtain from us the erasure of Personal Data concerning you when there is no good reason for us to continue Processing it.
- Request Restriction of Processing Your Personal Data. You shall have the right to obtain from us Restriction of Processing where one of the following applies:
❖ the accuracy of Personal Data is contested by you, for a period enabling us to verify the accuracy of Personal Data;
❖ Processing is unlawful and you oppose the erasure of Personal Data and request the restriction of their use instead;
❖ we no longer need Personal Data for the purposes of Processing, but they are required by you for the establishment, exercise or defence of legal claims; or
❖ you have objected to Processing of Personal Data concerning you on the basis of legitimate interest; pending the verification whether the legitimate grounds of us override those of you.
- Object to Processing of Your Personal Data. You shall have the right to object to Processing of Personal Data concerning you if:
❖ such data are processed for direct marketing purposes; or
❖ we use such data on the basis of legitimate interest for purposes other than direct marketing.
- Withdraw Your Consent to Our Using It. You should have the right to withdraw your Consent on using your Personal Data concerning you if the legal basis on which we use such data is Consent.
Data Sharing. We may share Personal Data concerning you with affiliated entities for business purposes. In addition, we may disclose and/ or share such Personal Data under the following circumstances:
- Authorized Service Providers. We may share Personal Data with select authorized third party service providers who provide us (including our affiliated entities) or you with products or services.
- Protecting Us and Others. We may access, preserve, and disclose Personal Data if required to do so or as reasonably necessary or appropriate for the following reasons:
❖ to comply with legal process;
❖ to respond to claims that any content violates the rights of third parties; and/ or
❖ to protect our (including affiliated entities, agents and customers) rights, property, or personal safe. This includes exchange of information with other organizations and authorities concerning cyberattacks, fraud prevention, spam/ malware prevention, and similar purposes.
- Business Transfer. As we continue to develop our business, we may buy, merge or partner with other third parties. In such transactions, Personal Data may be among the transferred assets.
Data Transfer. We operate globally and may transfer your Personal Data to our affiliated entities or Third Parties in locations around the world for the purposes described in the Policy. Wherever your Personal Data is transferred, stored or processed by us, we will take reasonable steps to safeguard the privacy of your Personal Data. These steps may include implementing standard contractual clauses where recognized by law, obtaining your Consent, or other lawful means of transferring Personal Data.
Data Retention. Your Personal Data will not be kept for longer than is necessary to fulfil the specific purposes outlined in the Policy and to allow us to comply with our legal requirements. After that, we will delete it.
Security. The security, integrity and confidentiality of your Personal Data are important to us. We have implemented appropriate technical and organizational measures that are designed to protect your Personal Data from unauthorized access, disclosure, use and modification. We also regularly review our security procedures to consider appropriate new technology and methods. Despite of our best effort, no security measures are perfect or impenetrable.
Changes to the Policy. We may update the Policy from time to time. When we post changes, we will revise the date of last modification at the top of the Policy.
If there are material changes to the Policy or in how we will use your Personal Data, we will notify you either by prominently posting a notice of such changes before they take effect or by directly sending you a notification. We encourage you to periodically review the Policy to learn how we is Processing Personal Data concerning you.
Contact Us. If you have any questions, or wish to exercise any of your rights, you can contact us by:
- E-mail: firstname.lastname@example.org
- Post: Unit A, 12/F, Casey Aberdeen House 38 Heung Yip Road, Wong Chuk Hang Hong Kong