隐私政策 - Edvance International

Edvance International Holdings Limited

This policy (“Policy”) sets out how Edvance International Holdings Limited and its subsidiaries (hereinafter referred to as “Edvance”, “we”, “our” or “us”) collect, use, store and handle personal data.

1. Our Pledge

We are committed to safeguard the privacy of individuals with respect to your personal data. We assure that our policies and practices, and those adopted by our affiliated companies in relation to the collection, use, retention, disclosure, transfer, security and access of your personal data comply with the requirements under the Personal Data (Privacy) Ordinance (Chapter 486) (the “Ordinance”) under the laws of Hong Kong, as well as the relevant code of practice and guidance issued by the Office of the Privacy Commissioner for Personal Data, Hong Kong. The meaning of the term “personal data” adopted in this Statement is defined in the Ordinance.

Where our operations are subject to privacy legislation other than that of Hong Kong (such as due to our carrying out of operational functions outside of Hong Kong), this Policy shall apply so far as it is consistent with such local legislation.

To ensure that you can make informed decisions and feel confident about providing your Personal Data to us, we outline in this Policy our practices and the choices you have concerning the collection and use of your Personal Data.

2. The Personal Data We Collect

The types of Personal Data we collect from you will depend on the specific type of services and products as requested by, or provided to, you. The types of Personal Data may include (without limitation) the following:

your personal information (e.g. your name, gender, date of birth, passport or other personally identifiable number);
your contact information (e.g. telephone numbers, mailing addresses, email addresses and fax numbers);
your business information (e.g. company name, business title and associated contact information);
your credit or debit or other charge cards information (e.g. name of cardholder, card number, billing address);
your interests, personal preferences or comments;
your comments and responses to market surveys, contests and promotional offers conducted by us or on our behalf; and/or
information when you use our websites or other services or products (e.g. behavioural information, purchasing history, location information, browser details, IP addresses).

Certain Personal Data (e.g. relating to your personal information and contact information) are required for specific services. Refusal to provide such information may render us unable to handle any products, services or request you are making, or may deny you access to certain parts of our websites, or may otherwise defeat the objectives of your visit. If you are under the age of 18, consent from your parent or guardian is required before you provide us with any personal data.

3. Purposes for which your Personal Data are Collected and Used

The purposes for which your Personal Data are collected and used may include (without limitation) one or more of the following purposes:

for the supply of any services, products, facilities and/or other subjects (together, the “Services”) which we or any of our subsidiaries and associated companies (together, “Edvance Group”) may offer to you, or you may require from us, from time to time;
for payment purposes for any of the Services of Edvance Group, including verification of credit card details with third parties;
for use of the online services available at any of the websites of Edvance Group and/or through other telecommunication channels;
with your consent, for marketing or promoting any of the Services of Edvance Group (e.g. sending you updates on our latest offers and promotions in relation to any of our Services from time to time);
with your consent, for promoting and soliciting donations or contributions for charitable or nonprofit making causes;
for development, sale or purchase of any of the Services of Edvance Group and/or for management or other related services;
for identification and verification purposes in connection with any of the Services that may be supplied to you;
for communicating with you by email, mail, fax, phone or other means, including contacting you regarding your enquiries;
for conducting research and/or analysis from time to time to better understand your preferences, interests, experiences and/or habits;
for designing new and/or enhancing existing Services, activities, contests and/or other events (together, the “Activities”) relating to Edvance Group’s products and services
for managing customer relationship
for making disclosures when required by law, regulation, or court order of any jurisdiction and/or as requested by any government, regulatory or law enforcement authority or administrative organization, which may be within or outside The Hong Kong Special Administrative Region of the People’s Republic of China (“Hong Kong”);
for establishing legal claims or defences, obtaining legal advice, and/or exercising, defending and/or protecting the rights or properties of any member of Edvance Group, including identifying, contacting or bringing legal action against any person who may be causing interference with such rights or properties (whether intentionally or otherwise) or where any other person could be harmed or property of any other person could be damaged by such interfering activities;
for the use by any member of Edvance Group in connection with any of the above purposes and/or any of the Services that any member of Edvance Group may offer or supply to you from time to time; and/or
for any other incidental or associated purposes relating to the above, or any other purposes as specified in a personal information collection statement when your Personal Data is being collected, or any other purposes which you may from time to time agree.

We will not knowingly or intentionally use, share or sell your Personal Data in ways which are unrelated to the above purposes (or purposes as specified in a personal information collection statement when we collect your Personal Data) without your prior consent.

4. Disclosure and Transfer of Personal Data

To facilitate the purposes mentioned under “3. Purposes for which your Personal Data are Collected and Used”, we may transfer, disclose, grant access to or share your Personal Data with third parties located within or outside Hong Kong, and your Personal Data may be transferred within or outside Hong Kong. These third parties may include the following:

any member of Edvance Group;
any agent, contractor or third party service provider who provides administrative, marketing, research, distribution, data processing, telemarketing, telecommunications, computer, payment or other services to or support the operation of Edvance Group’s business (including its/their direct marketing activities);
other business associates such as loyalty program operators and other companies involved in providing customer service or fulfilling customer requests;
credit reference agencies, credit, debit and/or charge card companies and/or banks;
medical professionals, clinics, hospitals, insurers and/or loss adjustors;
any person, government or law enforcement authority or administrative organization;
any person under a duty of confidentiality to any member of Edvance Group (including accountants, legal advisers or other advisers);
any actual or proposed assignee or purchaser of all or any part of the business and/or asset of Edvance Group; and/or
charitable or non-profit marking organizations.

The Personal Data you provide to us may also be sourced from or transferred to other jurisdictions outside Hong Kong for the purposes mentioned above.

5. Direct Marketing

If we intend to use your Personal Data (including your name and contact details) collected from you for direct marketing purposes (e.g. to send you marketing communications about news, offers or promotions in relation to the Services or Activities of Edvance Group), we will first obtain your consent (or an indication of no objection) before doing so.

If we intend to provide your Personal Data (including your name and contact details) collected from you to third parties for their use in direct marketing, we will first obtain your consent (or an indication of no objection) before doing so.

If you agree to receive marketing communications but do not wish to receive them in the future, you may opt out of receiving them at any time, free of charge, by the following applicable means:

unsubscribing by following the “Reply To” instructions contained in the marketing text message;
following the unsubscribe instructions or hyperlink in the email;
notifying us that you no longer wish to receive marketing communications when receiving our marketing calls; or
contacting us at the address stated in paragraph 10 below to tell us that you no longer wish to receive marketing communication through any channel.

6. Use of Cookies and Log Files

If you visit any of our websites, we may use cookie files to store and track information about you and your preferences. Cookies are small computer files that can be stored in web surfers’ computers for the purposes of obtaining configuration information and analyzing web surfers’ viewing 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 may refuse to accept Cookies by modifying the relevant Internet options or browsing preferences of your computer system, but to do so you may not be able to utilize or activate certain available functions in our websites. Our websites may bar users who do not accept Cookies.

Only the information that you provide, or the choices you make while visiting a website, can be stored in a cookie. For example, the site cannot determine your email name unless you choose to type it. Allowing a website to create a cookie does not give that or any other site access to the rest of your computer, and only the site that created the cookie can read it.

We may also collect information regarding your IP address, browser type, domain name and access time. This information is used for our own research purposes. As it is not linked to any personal information, it is separate from your Personal Data. In rare instances, IP addresses may be used to assist in deterring and/or preventing abusive or criminal activity on the website.

If you interact with us on social media platforms (for example if you “Like” our Facebook Page or post on our timeline), we can interact with you and send you messages via these platforms. We will interact with you in accordance with the social media platform’s rules, but we are not responsible for how the platform operators collect and handle your Personal Data.

7. Data Retention

If you are a customer of ours, your personal data which you have given us via application form, internet or other means, during the service subscription period will be retained for a reasonable period after termination of your subscription. We will erase any unnecessary personal data from our system in accordance with our internal policy.

8. Security of Personal Data

We use various encryption techniques to transmit via the Internet your personal data, which can only be accessed by our authorized personnel. Given the operational nature of the Internet, we cannot guarantee that the transmission is fully secure.

Our websites have firewalls in place, which should protect the Personal Data collected from you against unauthorized or accidental access. However, complete confidentiality and security is not yet possible over the internet, and privacy cannot be assured in your communications to us. You are encouraged to protect against unauthorized access to your password and credit card details. Make sure you sign out from your account when finished particularly when using a shared computer.

9. Other Websites

In order to anticipate your needs, our websites may contain links to third party sites that are operated under different privacy practices.

All such websites are independent from our websites. We have no control over the contents of such other websites or their privacy policies or compliance with the law. You should therefore be fully aware the provision of such links does not constitute an endorsement, approval, or any form of association by or with Edvance Group. We have no control over Personal Data that is submitted to these other websites. You should remain alert when you leave our websites, and read the privacy statements of other websites.

10. Your Rights and Contacting Us

Whenever we process Personal Data, we take reasonable steps to keep your Personal Data accurate and up-to-date for the purposes for which they were collected. We will provide you with the ability to exercise the following rights under the conditions and within the limits set forth in the law, subject to confidentiality obligations:

the right to access your Personal Data as processed by us and, if you believe that any information relating to you is incorrect, obsolete or incomplete, to request its correction or updating;
the right to withdraw your consent at any time, without affecting the lawfulness of the processing before such withdrawal. If you wish to withdraw the consent, please use the “unsubscribe” option in the digital messages we send to you or contact us directly.
the right to object, in whole or in part, to the processing of your personal data.

If you have a question about our Privacy Policy or wish to exercise any of the above rights, you may email us at info@edvanceintl.com or write to us at the following address:

Edvance International Holdings Limited
25th Floor, Tower 1, The Millennity,
98 How Ming Street, Kwun Tong, Kowloon,
Hong Kong

For your protection, we may only implement requests with respect to the personal information associated with the particular email address that you use to send us your request, and we may need to verify your identity before implementing your request. To the extent permitted by relevant laws and regulations, we reserve the right to refuse unreasonable requests (for example, requests which infringe the privacy of others). To the extent permitted by relevant laws and regulations, we reserve the right to charge a reasonable fee for the cost of processing any request set out above.

11. Note

You may access and obtain a copy of this Policy, as amended from time to time, at www.edvanceintl.com so that you are always informed of the way we collect and use Personal Data.

Please note that this Policy is written in the English language and may be translated into other languages. In the event of any inconsistency between the English version and the translated version of this notice, the English version shall prevail.

3/2020