This policy statement provides information on the obligations and policies of the subsidiaries, affiliates, and associated companies of E & B Company (hereinafter collectively referred to as the “Company”) under the Hong Kong SAR Personal Data (Privacy) Ordinance Cap.486 (the “Ordinance”).
Although this policy specifically addresses the Company’s obligations in respect of the laws of the Hong Kong SAR, the Company believes the principles embedded in the Ordinance are equal to any in the world in respect of the protections they provide to an individual. As such, the Company undertakes to apply, where practicable, those principles and the processes set out herein to its operations globally.
Where the Company’s operations are subject to privacy legislation other than that of Hong Kong SAR, then this policy shall be applied so far as practicable and consistent with such local legislation
Throughout this policy, our use of the term “personal data” has the meaning ascribed to it by the Ordinance.
OUR CORPORATE POLICY
The Company shall fully comply with the obligations and requirements of the Ordinance. The Company’s officers, management, and members of staff shall, at all times, respect the confidentiality of and endeavor to keep safe any and all personal data collected and/or stored and/or transmitted and/or used for, or on behalf of, the Company.
The Company shall endeavor to ensure all collection and/or storage and/or transmission and/or usage of personal data by the Company shall be done in accordance with the obligations and requirements of the Ordinance.
Where an individual legitimately requests access to and/or correction of personal data relating to the individual, held by the Company, then the Company shall provide and/or correct that data in accordance with the times and manner stipulated within the Ordinance.
PERSONAL INFORMATION COLLECTION STATEMENT
Types of Personal Data Collected
For the purpose of carrying on the Company’s business, including registration and administration of the Company’s website and related products and services (including relevant online services), you may be requested to provide personal data such as, but not limited to, the following, without which it may not be possible to satisfy your request:
a. Your name;
b. Contact details, including contact name and telephone number or email address.
In some instances, you may also be requested to provide certain data that may be used to further improve our products and services and/or better tailor the type of information presented to you. In most cases, this type of data is optional although, where the requested service is a personalized service, or provision of a product is dependent on your providing all requested data, failure to provide the requested data may prevent us from providing the service to you. This type of data includes, but is not limited to:
a. Your age;
c. Salary range;
d. Education and Profession;
e. Hobbies and leisure activities;
f. Other related products and services subscribed to; and
g. Family and household demographics.
The Company’s Web servers may also collect data relating to your online session, the use of which is to provide aggregated, anonymous, statistical information on the server’s usage so that we may better meet the demands and expectations of visitors to our sites. This type of data may include, but is not limited to:
a. The browser type and version;
b. Operating system; and
c. The IP address and/or domain name.
When you browse the Company’s website(s), the Company will record your visit only and will not collect any personally identifiable information from you unless otherwise stated. Cookies used (if any) in any part of our website(s) will not be deployed for collecting personally identifiable information. For your information, Cookies are computer files which will be stored in web surfer’s computer for the purposes of obtaining configuration information and analyzing web surfers’ viewer habits. They can save you from registering again when re-visiting a website and are commonly used to track your preferences in relation to the subject matter of the website. You have a choice not to accept the Cookies, but to do so you may be unable to utilize or activate certain available functions on the Company’s website(s).
Use of Personal Data
The personal data provided by you to the Company may be used for the following purposes (“Purposes”):
a. Registration of membership on the Company’s website(s) in order to utilize and/or activate certain functions of the website(s);
b. Providing and delivering to you the products/services which you order, subscribe or request and communicating with you regarding the products/services concerned;
c. Carrying on the Company’s business, including registration and administration of the Company’s website(s);
d. Carrying out data sorting and analysis to enable the Company to better understand your characteristics and buying behavior and to provide other services better tailored to your needs, and to assist the Company in selecting products and services which are likely to be of interest to you;
e. Aggregated customer behavioral analysis, and any other analysis, research or study on any product/service of the Company;
f. Direct marketing to you and for distribution of E & B Company newsletter (if any);
g. Any other normal administration, management, operation and maintenance of the Company’s product/service/website(s); and
h. As required by law.
Retention of Personal Data
The Company will destroy any personal data it may hold in accordance with its internal retention policy. The policy states that:
a. Personal data will only be retained for as long as is necessary to fulfill the Purposes for which it was collected unless the personal data is also retained to satisfy any applicable statutory or contractual obligations; and
b. Personal data are purged from the Company’s electronic, manual, and other filing systems in accordance with specific schedules based on the above criteria and the Company’s internal procedures.
Disclosure of Personal Data
All personal data held by the Company will be kept confidential but the Company may, where such disclosure is necessary to satisfy the Purposes, provide such information to the following parties:
a. Any subsidiaries, holding companies, associated companies, or affiliates of, or companies controlled by, or under common control with the Company;
b. Any person or company who is acting for or on behalf of the Company, or jointly with the Company, in respect of the Purposes;
c. 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; and
d. Any person or persons that have a right under the Ordinance to gain access to such information provided they are able to prove their authority to access such information.
e. Any party as ordered by the court or competent authority. For example, if the Company was served with a court order demanding certain customer information then the Company would disclose the information to the duly appointed officer of the court or such other persons as the court orders.
Any enquiry regarding compliance with the liability of the company, please contact to:
6403 4156 or email to firstname.lastname@example.org