At our website (“we”) it is important to us that we manage your personal information securely and consistently with relevant legislation, including the Privacy Act 1993 (“Privacy Act”).

This Policy outlines how we and our related companies collect, disclose, use, store or otherwise handle personal information.

This Policy explains:

• The kinds of personal information we collect, and the purposes for which we do that;
• How we manage the personal information that we collect about you;
• How you can seek access to and correction of that information;
• If necessary, how you can make a complaint relating to our handling of that information.

This Policy is not limited to current customers but to all individuals who deal with us.

Application Of This Privacy Policy

1. We are a proprietary company that operates across HK. We provide products to customers under layby sale agreements.
2. We are governed by the HK Privacy Principles under the Privacy Act. These set out the way organisations and government agencies can collect and use, disclose and provide access to personal information.
3. Personal information is information about an identifiable individual; and includes information relating to a death that is maintained by the Registrar-General pursuant to the Births, Deaths, Marriages, and Relationships Registration Act 1995, or any former Act (as defined by the Births, Deaths, Marriages, and Relationships Registration Act 1995).
4. We respect your personal information, and this Privacy Policy explains how we manage it. This Privacy Policy covers and all of its related companies.
5. Notwithstanding any references or specific examples in this Privacy Policy, those examples are not an exhaustive list of personal information collected by us.

Why We Collect And Use Personal Information

5. We take your personal privacy seriously. We may collect personal information about you:(a).because you have provided it directly to us, for instance contact details, date of birth, and credit card numbers or bank account details;(b)because an applicant for a layby agreement has provided your details to us as a personal referee;(c)because a recruiter or other similar service provider has provided your details to us in relation to a position working with us;(d)to provide a service that you have requested such as providing details to another company for the allocation of reward or points;(e)to process your layby sales application and/or request for services;(f)to provide you with the most appropriate services for your needs;(g)to improve our services, for instance, through the collection and analysis of statistical and research data and use of cookies;(h)because you provide services or goods to us;(i)for purposes directly related to any of the above and any of our services;(j)to provide follow-up on information regarding We, including responding to comments or questions or providing our services to you;(k)to meet any requirements of government funding for programs including receiving, collecting and collating de-identified statistical information;(l)to monitor and evaluate existing services and plan for future services; and(m)if we are required to share your information with government or regulatory bodies, as required or authorised by law.
6. We only use your personal information for purposes which are directly related to the reason it was provided to us in the first place and where you would reasonably expect us to use your information. This may include sharing your personal information with other service providers (including delivery service providers, marketing service providers, IT product and service suppliers and our direct debit banking merchants.)
7. Examples of where we might collect and use personal information include:(a)Processing your application and request/s for products and/or services;(b)Considering your eligibility for our products and/or services;(c)Administering your account including requests and the provision of products and/or services;(d)Providing reports on your product and/or services activities as requested by you;(e)Delivering products and/or services to you via the post where our employees and/or a Service Provider will need to know at a minimum your name and address in order to deliver the services and products;(f)Letting you know of special offers or discounts from us or our partner organisations that are available to you; and(g)Considering a job application or résumé you send to us.
8. We may share your information with government or regulatory bodies (such as the

IRD and Commerce Commission) as required or authorised by law. These agencies may also share this information with organisations or agencies outside HK.

How We Collect Information

9. Whenever possible, we will collect personal information directly from you unless unreasonable or impractical for us to do so. We may also collect personal information in a variety of ways, including but not limited to when you:
10. use our website;
11. phone us;
12. write to us;
13. email us;
14. visit us in person;
15. provide feedback to us; and
16. purchase or use our products and/or services.
17. There are certain instances in which we will collect information about you from third parties where it is unreasonable or impracticable to collect it directly from you. For example, we may collect your personal information from an individual who provides your details as a person referee or from a recruiter proposing you for a position with us.

Disclosure Of Personal Information

Disclosure of personal information to third parties

1. We will not disclose your personal information to another person unless you have given consent or if one of the exceptions under the Privacy Act applies. Where possible, the information that could reasonably identify you as an individual is first removed.

Exceptions

Except as set out above, We will not disclose your information to a third party unless one or more of the following applies:

you have given your consent for us to do so;

you would reasonably expect us to use or give that information for another purpose related to the purpose for which it was collected;

it is otherwise required or authorised by law;

it will prevent or lessen a serious threat to somebody’s life, health or safety or to public health or safety;

it is reasonably necessary for us to take appropriate action in relation to suspected unlawful activity, or misconduct of a serious nature that relates to our functions or activities;

it is reasonably necessary for the enforcement of a law conducted by an enforcement body.

Examples

Customer Records: We maintains records of all customers including financial information which may need to be shared with financial institutions, government or regulatory bodies from time to time.

Product Delivery: Our products may be delivered to you by a third party courier organisation. In order to deliver these products we will have to disclose your name, address and, in some circumstances (such as with dangerous or hazardous materials), the nature or contents of the package.

Disclosure Of Information To Third Parties Overseas

We may disclose personal information to our service providers that are based in HK including our IT product and service suppliers and our direct debit banking merchants. We undertake to protect your personal information by ensuring the country in which those providers are located has similar protections in relation to privacy, or that we enter into contractual arrangements with the organisation or agency to ensure the protection of your privacy. We regularly shares information with related organisations in HK.

Can I Remain Anonymous?

It is your choice to provide information to us. Wherever it is lawful and practicable, you have the option not to identify yourself or to use a fictional name when interacting with us. You can remain anonymous when using some parts of our website, or sites administered by us.

It may be necessary for us to collect your personal information if you would like certain products or services. If you choose to withhold the information we require, we may not be able to provide you the products or services you have requested.

Security And Storage Of Your Information

We store your information in a number of ways including physically (such as in paper form) or electronically with third party data storage providers. Your privacy and the security of your information is very important to us so where we store your information with third party providers, we will enter into contractual arrangements with those providers to ensure they take appropriate measures to protect your information.

We take appropriate steps to protect your personal information held by us from misuse, interference, unauthorised access, modification, loss or disclosure. This includes during storage, collection, processing and transfer and destruction of the information. These steps include but are not limited to:

ensuring our computer systems and websites have security systems in place such as up to date firewall and data encryption;

maintaining security systems and monitoring of our premises;

implementing confidentiality agreements with our employees and contractors, sub-contractors ,service providers and their agents;

requiring all employees and contractors who handle, deal or work with personal information in the course of their duties with us to undergo training on our Privacy Policy and procedures and information and data storage management, before undertaking those duties

maintaining document storage security policies and procedures; and

implementing verification procedures for all inquiries/transactions to ensure only authorised people can access personal information.

Our website may contain links to external websites. We recommend that you review the privacy policies of those external websites as we are not responsible for their privacy practices.

How To Access And Correct Your Information

We will take reasonable steps to ensure that all personal information we collect, use or disclose is accurate, up-to-date, complete, relevant, and not misleading.

We will correct any personal information that we believe to be incorrect, out-of-date, incomplete, irrelevant or misleading. This may include taking reasonable steps to notify any organisation or government agency to which information was disclosed about the correction. You may request to access or correct your personal information at any time by contacting the Privacy Officer using the contact details below. We will give you access to your information unless one of the exceptions under the Privacy Act applies.

For example, if providing access would be unlawful.

If you request to access or correct your information, we will respond within a reasonable time (usually within 30 days). If your request is refused, we will give you a written notice that sets out the reasons for refusal and how to complain about the decision.

Direct Communications And Promotional Materials

From time to time, we may send out promotional materials and information from government departments or other third parties.

If you do not wish to receive these communications, please contact us to unsubscribe from that mailing list.

Your information may also be used by us to provide you with details of other organisation’s services where permitted by the Privacy Act or where you have consented to the use or disclosure of your personal information for direct communications and promotional materials.

It is our policy that any direct communications or promotional material will include a statement advising that you can request to not receive further material from us by contacting us using the details provided. Please note that if you choose this option this will also prevent you receiving offers of discounts and notices of upcoming promotions as well as other informational materials relating to our products.

Cookies

The We website and sites administered by us use software known as

‘cookies’ to record your visit to the website and collect some statistical information.

We use this information to help administer and improve our websites. We do not use this information to personally identify you. Information we may collect includes:

your computer’s IP address;

your domain name;

the date and time or access to the website;

pages accessed and documents downloaded;

the previous sites visited

if you have visited the website before; and

the type of browser software in use.

You may set your browser to disable cookies when visiting our websites. However, some of our website functions may be unavailable if you choose to do so.

Updates To Our Privacy Policy

We will update our Privacy Policy from time to time. Our website will have the most current Privacy Policy.

Complaints And Enquiries

We are committed to the protection of your privacy. If you have any questions about how we handle personal information, we would like to complain about how we have handled your information, or would like further information about our Privacy Policy, please submit a query or complain to our Privacy Officer. Our privacy officer will assess any complaints and liaise with you to resolve and any issues within a reasonable time.

If you consider your privacy concerns have not been resolved satisfactorily by us, of you wish to obtain more information on privacy requirements you can contact The Office of the HK Privacy Commissioner