Although this policy may specifically address the Company's obligations in respect of the laws of the Hong Kong SAR Personal Data (Privacy) Ordinance Cap.486 (the "Ordinance"), 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, address 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 you 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 non-personal 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 information is not intentionally gathered in a fashion to personally identify any single user. This type of data may include, but is not limited to:
a. The browser type and version;
b. Operating system;
c. Your approximate geographic location based on your IP address;
d. Any interaction you may initiate within the website; and
e. The IP address and/or domain name.
The Company does not knowingly allow any visitors or users under the age of eighteen (18) or the age of majority in his/her relevant jurisdiction to use or otherwise access to the website. The Company does not wish to collect any personal data (or any information at all) from any persons under 18 years old. If you are under 18 years old, you may not use the Company’s website(s).
a. measure usage of various pages on our website to help us make our information; more pertinent to your needs and easy for you to access; and
b. identify and categorize the internet webpages from which the visitor came to the website and observe the browsing patterns.
You have a choice not to accept the Cookies, although doing so may adversely affect your ability to perform certain transactions, use certain functionality and access certain content on our website(s).
When you view the website, our servers automatically record information that your browser sends whenever you visit a website. These server logs may include information such as your web request, Internet Protocol address, browser type, browser language, the date and time of your request and one or more cookies that may uniquely identify your browser.
For California Users: Please note, the Company’s website(s) are not presently configured to respond to DNT or “do not track” signals from web browsers or mobile devices.
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 in 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 in respect of the Company’s sauces, condiments, food and/or lifestyle products and for distribution of the Company’s 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 fulfil 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;
e. 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; and
f. Any party as ordered by court or competent authority or if we, in our sole discretion, believe that disclosure is reasonable to (1) comply with the law, requests or orders from law enforcement, or any legal process (whether or not such disclosure is required by applicable law); (2) protect or defend the Company’s or a third party’s rights or property; or (3) protect someone’s health or safety, such as when harm or violence against any person (including you) is threatened. For example, if the Company were 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.
Security of Personal Data
Please note that data that is transported over an open network, such as the Internet or e-mail, may be accessible to anybody. We cannot guarantee the confidentiality of any communication or material transmitted via such open networks. When disclosing any personal data via an open network, you should remain mindful of the fact that it is potentially accessible to others, and consequently, can be collected and used by others without your consent. In particular, while individual data packets are often encrypted, the names of the sender and recipient are not. A third party may therefore be able to trace an existing relationship or one that is subsequently created. Even if both the sender and recipient are located in the same country data may also be transmitted via such networks to other countries regularly and without controls, including to countries that do not afford the same level of data protection as your country of domicile.
Password-protected areas of the website can be accessed only with a valid user name and password. Each password owner is responsible for keeping the password confidential and safe, as the Company has no control or responsibility for this type of user information. If the password may have been stolen or might otherwise be misused, it is the responsibility of the password owner to notify the Company immediately for further action.
Physical records containing personal data are securely stored in locked areas and/or containers when not in use. Computer data are stored on computer systems and storage media to which access is strictly controlled and/or are located within restricted areas. Access to records and data without appropriate management authorization are strictly prohibited. Authorizations are granted only on a "need to know" basis that is commensurate with an individual's Company responsibilities and their training.
Records of the Company are under the control of assigned information officers who are responsible to ensure the transfer of or access to information is legitimate and complies with the Ordinance. Audit records may be produced to validate data modifications in order to verify the data's integrity.
There may be violations logging processes for investigation of any unauthorized attempt to access information. Encryption technology, such as SSL, may be employed for the transmission of data collected online.
Access and Correction of Personal Data
Under the terms of the Ordinance, individuals have the right to:
a. Check whether the Company holds any personal data relating to them and, if so, obtain copies of such data;
b. Require the Company to correct any personal data relating to them which is inaccurate for the purpose for which it is being used; and
c. Ascertain the Company's policies and practices in relation to personal data, which are those policies and practices set out in their entirety herein.
An individual may exercise his or her right of access by checking it online with assigned password and login name.
The Company will, upon satisfying itself of the authenticity and validity of the access request, make every endeavor to comply with and respond to the request within the period set by the Ordinance.
An individual may exercise their right of correction by login to personal data update with assigned password and login name.
The Company will, upon satisfying itself of the authenticity and validity of the correction request, make every endeavor to comply with and respond to the request within the period set by the Ordinance.
In accordance with the requirements of the Ordinance, the Company will honor an individual's request not to use his or her personal data for the purposes of direct marketing. The Company will not use or provide personal data to any person for use in direct marking without your consent or indication of no objection. Even you have indicated consent, you still have right to opt out from receiving direct marketing materials from us at any time. Should you wish to change your indication to receive or not to receive direct marketing material from the Company, please email to firstname.lastname@example.org, or adjust your email preferences or unsubscribe via the link in the newsletters.
(If there is any discrepancy/inconsistency between the English and Chinese version, the English version shall prevail.)
LINKS AND THIRD PARTIES’ PRIVACY PRACTICES
The Company’s website(s) may contain links to other websites. The Company is not responsible for the privacy practices or the content of these other websites. You will need to check the privacy policies of these other websites to understand their policies. When you access a linked site you may be disclosing private information. It is your responsibility to keep such information private and confidential.
The Company may use third party service providers to help operate its business and website(s) or administer activities on its behalf, such as sending emails. The Company may share your information with these third parties for such purposes.
The Company may also have relationships with third party service providers known as Ad Networks to serve ads on its behalf across the internet. Using Cookies and Pixel Tags (also known as Web Beacons), Ad Networks collect anonymous information about your visits to our website and other websites in order to deliver advertisements that may be of particular interest to you. This process does not involve the collection of any personally identifiable information. The Ad Networks do not know your name, phone number, address, email address or any personally identifiable information. The Company does not share any personally identifiable information about you with these advertising networks.
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