Privacy Policy

This Policy Statement provides information on the obligations and policies of Microworks Technology Limited and, its subsidiaries, affiliates, and associated companies (the “Company”) under the HKSAR Personal Data (Privacy) Ordinance – Cap. 486 (“the Ordinance”).

We respect the privacy rights of our customers and recognize the importance of protecting the information collected from you. This policy guides how we collect, store, and use the information that you provided and applies only to Website (“site”) maintained by the Company but no other companies or organizations to which we link. Throughout this policy, the meaning of the term “personal data” is as defined in the Ordinance.

This policy specifically addresses the Company’s obligations in respect of the data privacy laws of the HKSAR. Where the Company’s operations are subject to privacy legislation other than that of HKSAR, then this policy shall be applied so far as applicable and consistent with such local legislation.

The Company’s 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 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, storage, transmission and other handling or usage of personal data by the Company shall be done in accordance with the obligations and requirements of the Ordinance.

Type of Personal Data Collected

When you subscribe to be a member of our Company, you may be required to provide us your personal information of which the details are setting out in our Personal Information Collection Statement (PICS). The contents of PICS set out the purpose for such collection, the disclosure, retention and storage of your personal information. The contents of PICS may be changed or updated from time to time. Users are invited to check back periodically. The matters that are not addressed in PICS, this privacy policy shall apply.

When you come to our Site, for the purpose of carrying out the Company’s businesses, including sale, provision, administration of the membership services and related products and services, you may be requested to provide personal data such as

a. Account details;

b. Contact details such as contact name, telephone number or email address; or

c. Corresponding and/or billing address;

d. Information for the verification of identity.

e. Your name;

In some occasion, you may be requested to provide:

a. age;

b. education

c. gender;

d. hobbies

e. leisure activities,

f. salary range;

g. profession;

that may be used to further improve the Company’s products and services that presented to you. Failure to provide such requested data or information may sometimes defer or prevent us from providing the products or services to you.

The Site may also collect data relating to your online session, the use of which is to provide statistical information so that we can better the services and take necessary actions against any unscrupulous party who places any illegal or unlawful contents on any website through the Company’s web servers.

The types of data may include but are not limited to:

a. Operating system;

b. The browser type and version;

c. The IP address and /or domain name;

d. URLs.

Our Company’s Site may place a “cookie” on your machine. This personal information collected may include relevant login and authentication details as well as information relating to your activities and preferences across the Company’s Site. This is done without the users being aware that it is occurring. Generally cookies are used to estimate audience size, track users’ progress and number of entries in our promotional activities and to measure users’ traffic patterns.

Occasionally, you may need to provide personal data about other individuals to us (e.g. users whom you have subscribed for services on their behalf). In that event, for the compliance with the Ordinance, you are required to have first obtained the authorization of such individuals before using, disclosing and transferring their personal data, including giving consent on their behalf to our possible use, disclosure and transfer of their personal data, for the purposes you would want to achieve from us. If necessary, we may require you to provide us with any supporting document as may be necessary to prove such authorization. You should also advise them that we can be contacted for further information (please refer to the section titled “The Company’s Personal Data (Privacy) Ordinance Contact Details” for our contact details).

Use of Personal Data

Your personal data may be used for:

– any other purposes as may be agreed between you and the Company apart from this Policy.

– business planning and improving goods and/or services to you by the Company;

– checking of your credit, payment and/or status in relation to the supply of goods and services to you;

– disclosure as permitted or required by law; and/or

– enabling the daily operation of your membership account and/or collection of amounts outstanding in your account with the Company;

– handling of complaints and enquiries of the customers; and

– marketing and advertising of any goods and/or services to you by the Company, agents, contractors and third party upon your consent in accordance with the requirement of the Ordinance;

– processing of your application to subscribe to our services and loyalty programs;

– processing of any benefits or membership application in connection with the supply of goods and services to you;

– provision of goods, services and loyalty programs to you;

– processing of any payment instructions or credit facilities in relation to supply of goods and services to you;

– prevention, detection or investigation of crime;

– verifying your identity;

Accuracy of Personal Data

The Company may require validating the personal data provided to ensure accuracy or authenticity of the identity document supplied from you to us. We may request you to produce the identity document in person for

checking at a time convenient to you.

You have a right to request correction of your personal data and we recommend that you:

– let us know if there are any errors in your personal data; and

– keep us up-to-date with changes to your personal data such as your name or address.

Retention of Personal Data

The Company will destroy any personal data it may hold in accordance with its internal policy.

a. Personal data will only be retained for as long as is necessary to fulfill the original or directly related purposes for which it was collected, unless the personal data are also retained to satisfy any applicable statutory or contractual obligations; and

b. Personal data are purged from the Company’s electronic and other filing systems in accordance with the schedules based on the company’s internal procedures.

Disclosure of Personal Data

All personal data held by the Company will be kept confidential and will not be disclosed or transferred to any other party but the Company may, where such disclosure is necessary to satisfy the purpose, or a directly related purpose, for which the data was collected, provide such information to the following parties:

a. any subsidiaries, associated companies, or affiliates of, or companies controlled by, or under common control with or within the Company upon your consent in accordance with the requirement of the Ordinance;

b. any person who is acting for or on behalf of the Company or jointly with the Company, in respect of the purpose or a directly related purpose for which the data was collected, for administrative and other purposes deemed necessary to maintain service and improve service ;

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;

d. the Company’s dealers, agents, contractors, suppliers and other telecommunication, information service providers and content providers; its professional advisers, including its accountants, auditors and lawyers;

e. Government and regulatory authorities and law enforcement agencies and other organizations as required or authorized by law;

Transfer of Personal Data Outside Hong Kong

It may be necessary for the Company to transfer certain personal data to places outside the HKSAR in order to carry out the purposes or directly related purposes, for which the personal data were collected. Where such a transfer is performed, your consent in accordance with the requirement of the Ordinance will be obtained.

SECURITY OF PERSONAL DATA

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.

Where the Company holds, uses and/or transmits the Customers’ personal data it will be adequately protected from accidental and/or unauthorized disclosure, change and/or destruction.

You should be aware that no system is impenetrable and no information provided over the Internet can be guaranteed to be completely secure. Accordingly, we cannot guarantee the security of any information that you transmit to us or receive from us over the Internet.

LINKS TO THIRD PARTY WEBSITES

Our websites may contain links to other sites and pages which are operated by third parties. We have no control over the content of the linked websites or the way in which the operators of those websites deal with your personal data. You should review the privacy policy for those third party websites to understand the ways in which your personal data may be used by those third parties.

Access and Correction of Personal Data

a. You have the right to request access to and correction of personal data in its possession which is inaccurate for the purpose for which it is being used by means of a data access request (“right of correction”). You have further right to ascertain whether the Company holds any personal data relating to you and, if so, obtain copies of such data (“right of access”).

b. You may exercise his or her right of access by completing the “Data Access Request Form” as prescribed under the Ordinance and sending the completed form to us. Our staff will make a call to you after receiving the completed form and respond to your request upon authenticity and verification is satisfied.

Direct Marketing

The Company will honor your request not to use his or her personal data for the purpose of direct marketing unless your consent is obtained. You may at any time send request to our Customer Services Centre with registered name and contact telephone number to stop receiving the promotion materials or to start receiving the same.

Handling of Personal Data for Recruitment and Employment

We have our Personal Information Collection Statements (PICS) for recruitment and employment of staff purpose. They set out the purposes for personal data collection and their handling. The matters that are not addressed in PICS, this privacy policy shall apply.

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