We pledge to meet fully, and where possible, exceed internationally recognized standards of personal data privacy protection, in complying with the requirements of the Personal Data (Privacy) Ordinance, Chapter 486 of the laws of the Hong Kong SAR ("Ordinance"). In doing so, we will ensure compliance by our staff with the strictest standards of security and confidentiality.
It is the policy of our Group (or interchangeably "We" as hereinafter mentioning and collectively means SUNeVision Holdings Limited and its subsidiaries) to safeguard all information provided by Users (meaning our web site users). We do not collect any personally identifiable information ("Personal Data") from Users during their browsing of our web sites. When Users visit our web sites we record their visit only as a 'hit' and do not collect any Personal Data from them. We will however make a record of their visit that shows only the Domain Name Server address, part of their e-mail address, and of the pages visited. We use such information only for preparing general statistics on the usage of our web sites.
If Personal Data are collected in the process of making enquires or submitting applications for services provided by different operations within our Group, Users will be informed via the respective Personal Information Collection Statements of our web sites of such purposes and uses, including the extent of their transfer and disclosure; and the right of access to and correction of the collected Personal Data.
In order for us to provide Users with customisable and personalised services, we use 'cookies' to store and sometimes track information about Users. The information collected by means of 'cookies' includes Users' log-in name and his or her navigation pattern. This is done without Users being aware that it is occurring. Generally, we use 'cookies' to estimate our audience size; to track Users' progress and number of entries in our promotional activities; to assist merchants in tracking visits to, and business at, their stores, and to measure Users' traffic patterns. Personal Data collected by means of 'cookies' will not be disclosed to any third parties except to those parties within our Group and the SHKP Group (i.e. Sun Hung Kai Properties Limited and its subsidiaries).
Once we have obtained User's Personal Data, it will be maintained securely in our system. We shall retain Users' Personal Data for so long as he or she is a registered user of our Web sites. Only the authorised staff, who have been properly trained, will be permitted access to such Personal Data, and we shall not release such Personal Data to any external parties except those parties set out in our Personal Information Collection Statement without User's agreement.
We may from time to time send direct marketing materials promoting products and services to Users based on their Personal Data but shall stop doing so when being advised in writing that Users do not wish to receive further materials from us. Suitable opt-out facilities will be provided during the direct marketing process.
We shall make our best endeavour to ensure that the privacy of Users is properly protected. However, given the nature of the Internet, we cannot guarantee that there is "perfect security".
Personal Information Collection Statement
Our Group [or interchangeably "We" as hereinafter mentioning and collectively means SUNeVision Holdings Limited, its subsidiaries and associated companies, including Sun Hung Kai Properties Limited and its subsidiaries ("SHKP Group")] is committed to safeguarding your privacy on-line. This statement is given in compliance with the requirements of the Personal Data (Privacy) Ordinance, Chapter 486 of the Laws of the Hong Kong SAR, to notify you of certain matters when collecting information from you. This statement may change from time to time, so please check back periodically. By subscription and every time you log-in to this Web site to use our services, you agree to be bound by this statement at that time in force and agree to us (i.e. any person or bodies corporate or division within our Group, including SHKP Group) using, disclosing and transferring your data for the purposes and in the manner set out herein.
Collection of Data
At the time of subscription and at other times when using this Web site, you may be asked to provide us with personally identifiable information, such as your name and e-mail address. It is necessary for us to collect your information for providing you the various services and activities offered on this Web site. If you fail to provide the information requested, we will not be able to provide you the services and activities available on this Web site.
Purpose and Use of Data
The information we collected will be used for the following purposes:-
- to monitor use of this Web site and to help its further development;
- to compile aggregate statistics about our users and to analyse site usage;
- to collect data for identity verification and records and to maintain contact lists for correspondence;
- to deliver information to you that we believe you may have interest in, such as targeted banners, new services and products and other promotions and marketing materials;
- to contact you regarding administrative notices and communications relevant to your use of this Web site and to respond to your request.
We may also use your information to match user information with third party data (i.e. to compare two sets of personal data collected for different purposes). By subscribing to this Web site or by logging-in, you consent to carry out this matching procedure when we deem it is necessary in order to provide our services.
In addition, we will also use your information in the following manner:-
- We will share much of our data, including your information, with our business partners, subsidiaries and associated companies, including SHKP Group.
- In order to provide you with more information and services, we have arranged content providers and service providers to provide information and services. It may be necessary for us to share your information with these content providers and service providers.
If we add new features or services that might require the sharing of your personal information with an additional advertiser or sponsor, we will provide you with notice and the opportunity to opt-out to receive these offers.
Transfer of Data
Your information will not generally be disclosed or transferred to any other party in a form that would identify you except in the following circumstances:
- If we use third party suppliers or service providers to facilitate our services, we will have to provide your information to these suppliers or service providers offering such services where you choose to use these services.
- We may disclose or access account information when we believe in good faith that the law requires it.
- We may also disclose or access account information for administrative and other purposes that we deem necessary to maintain, service, and improve our services.
In addition, your information will be accessed by, disclosed or transferred to our business partners, any person or bodies corporate or division within our Group and SHKP Group.
As the parties mentioned above may have places of business outside Hong Kong, your information may be transferred out of Hong Kong. By subscribing to our Web site or by logging-in, you agree to us transferring your information to these parties outside Hong Kong. These third parties adhere to their own privacy customs and policies and we have no control over their use of your information. Therefore, we are not liable to their use of your information.
Access to Data
You have the right to request access to, and correction of, information about you held by us. If you need to check whether we hold your personal information or if you wish to have access to your information and/or to correct any information relating to you which is inaccurate, please fill in the data access request form below and e-mail it to our Data Protection Officer at firstname.lastname@example.org You agree to pay us the reasonable charges incurred by us in relation to administering and complying with your request.
Personal Data Access Request Form
PERSONAL DATA (PRIVACY) ORDINANCE
This Form is prescribed by the Privacy Commissioner
DATA ACCESS REQUEST FORM1
for Personal Data. It should be submitted to the party holding personal data.
(Read this Form and the accompanying Notes carefully before completing the Form.)
To _________________________________2 (for the attention of___________________________3)
1. The Data Subject
This is a data access request under section 18(1) of the Personal Data (Privacy) Ordinance ("the Ordinance") concerning the personal data of the following individual (hereinafter referred to as "the data subject"):
Name in English: (surname) ___________________________________________________
(other name) _________________________________________________
Name in Chinese (if any): (surname) ____________________________________________
(other name) __________________________________________
Hong Kong Identity Card Number4: ____________________________________________
Personal identifier (e.g. student no., staff no., medical no.) previously assigned by your organization5 (if any): _______________________________________________________
2. The Requested Data
Save as excluded under paragraph 3, this data access request covers the personal data of the data subject as defined below (hereinafter referred to as "the Requested Data"):
Type or other description of the Requested Data (e.g. medical records, personnel records, records relating to a particular incident, etc.): ___________________________________________
Date around which or period within which the Requested Data were collected (if known)6:
Branch or staff member by whom the Requested Data were collected (if known):
For the avoidance of doubt, the Requested Data access to which is sought do not include any personal data7:
contained in documents previously provided to your organization by the data subject(e.g. letters to your organization from the data subject) contained in documents already provided to the data subject by your organization (e.g. letters to the data subject from your organization or documents provided pursuant to a previous request) in the public domain (e.g. newspaper clippings or entries in public registers concerning the data subject)
(other excluded personal data) : _____________________________________________
4. The Request
I hereby request your organization:
pursuant to section 18(1)(a) of the Ordinance, to inform me whether your organization holds the Requested Data pursuant to section 18(1)(b) of the Ordinance, if your organization holds any of the Requested Data, to supply me with a copy of such Data that your organization holds
5. Preferred Manner of Compliance
In your complying with this data access request, I would prefer that your organization8:
gives me an indication, before processing my data access request, of any fee that may be charged for compliance with my request9
notifies me when a copy of the Requested Data is ready for collection
sends by registered mail a copy of the Requested Data to me at my address given in this Form
sends by ordinary mail a copy of the Requested Data to me at my address given in this Form
supplies to me a copy of the Requested Data in the _______________ language
supplies to me a copy of the Requested Data in the form of _______________ (e.g. computer disk, microfilm, etc.)
This data access request is made in my capacity as (tick one) :
the data subject
a relevant person10 of the data subject, in proof of which I enclose the following11:
7. Further Information
I understand that before complying with my request, your organization may require me to provide12:
proof of my identity;
where I am making this request as a relevant person, proof of the identity of the data subject and further proof (if any) of my status as a relevant person;
such further information (whether on a form issued by your organization or otherwise) as may be reasonable for your organization to locate the Requested Data.
8. Time for Compliance or Refusal
Please note that under section 19(1) of the Ordinance, your organization should comply with mydata access request within 40 days after your receiving this request. If your organization is unable or has valid ground to refuse to comply with the request, in accordance with section 19(2) or 21(1) of the Ordinance, your organization is required to give me notification of such matter within the same 40 day period. Failure to do so may constitute an offence under section 64(10) of the Ordinance.
9. Use of Personal Data
Except with the express consent of the individual concerned, the personal data provided in this Form may be used for the purpose of processing of the data access request and for directly related purposes only.
Name of requestor:(surname) ___________________________________ (other name) _________________________________
Correspondence address: ______________________________________________________
Day-time telephone number: _______________________
1. This Data Access Request Form is specified by the Privacy Commissioner for Personal Data under section 67 of the Personal Data (Privacy) Ordinance with effect from 1 December 1999. According to section 20(3)(e) of the Ordinance, a data access request may be refused if it is not made in this Form after the said date. Copies of this Form and an explanatory pamphlet are available at the Office of the Privacy Commissioner for Personal Data (PCO) and any District Office. The PCO is situated at Unit 2001, 20/F, Office Tower, Convention Plaza, 1 Harbour Road, Wanchai, Hong Kong. The PCO enquiry hotline is 2827 2827.
2. Fill in here the name of organization or individual to whom the data access request is addressed.
3. If you have previously been informed by the organization to whom the data access request is addressed of the name or title of the person in the organization to whom such a request may be made, fill in here the name or title of such person.
4. For data subjects who are Hong Kong Identity Card holders only. The identity card number need not be provided in this Form if you have reasonable grounds to believe that this will not be necessary for the unique identification of the data subject in the circumstances.
5. In this form, the term "your organization" means the party to whom the data access request is addressed, whether such party is in fact an organization or an individual.
6. For example, if the Requested Data relate to a particular incident, say, a medical consultation, fill in here the date of that consultation as best remembered. If the Requested Data relate to a particular period, for example, a period of employment, fill in here the relevant service period.
7. Tick to exclude, as far as possible, any personal data you do not wish to include within the scope of the Requested Data. This may help to avoid any unnecessary delay or charge in complying with the data access request (see Note 8 below).
8. Tick and fill in according to preference. However, compliance with the data access request may not be in the preferred manner where this is not reasonably practicable.
9. According to section 28 of the Ordinance, a fee may be charged for compliance with a data access request under section 18(1)(a) or (b), which fee must not be excessive. Compliance with a data access request may be refused unless and until any such fee has been paid.
10. Under section 2(1) of the Ordinance, a "relevant person", in relation to an individual, means:where the individual is a minor, a person who has parental responsibility over the minor;where the individual is incapable of managing his own affairs, a person appointed by the court to manage those affairs; or in any other case, a person authorized in writing by the individual to make the data access request.
11. Fill in here details of any documentary proof of "relevant person" status, e.g. copy birth certificate, copy court order, written authorization etc., which you will provide with the Data Access Request Form. See also paragraph 7(b) of the Form.
12. Failure to provide the additional information as required may result in the data access request being refused, or not being complied with to the desired extent.
13. Where the Form or these Notes contain a summary of the relevant requirements of the Ordinance,the summary is provided for reference only. For the complete and definitive statement of the relevant provisions of the Ordinance, please refer to the Ordinance itself.