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Privacy Policy Statement
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".
In order to provide you with more information and services, we
use third party content providers and service providers, and provide
links to other Web sites. These third parties may collect Personal
Data about you when you make use of their services. These third
parties adhere to their own privacy policies and practices and
our Privacy Policy Statement does not cover such third party practices.
Users may review and edit his or her
Personal Data on-line by visiting our Web sites. Should Users
have any queries about our privacy policy and practice, please
e-mail to our Data Protection Officer at mailto:dpo@sunevision.com
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 operate internal control,
resolve disputes, troubleshoot problems and enforce our terms
of use ;
- 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.
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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.
Please also see our Privacy
Policy Statement which sets out
our general privacy policy and practices in respect of our collection,
holding and 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 dpo@sunevision.com
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): _________________________________________________________________________
3.
Exclusions
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.)
6.
Capacity
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: _______________________
Date: _________________________
Signature:
_______________________________________
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NOTES
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 isaddressed 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.
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