We value your privacy and are committed to protecting the privacy and security of your personal information provided to us in accordance with the Personal Data (Privacy) Ordinance (Cap. 486) (“PDPO”). This includes personal information provided by visitors to our website and to all the associated pages (collectively, the “Website”) under the direct control of us. Our Website uses ‘cookies’ and ‘cookies’ may also be used at certain third-party websites accessible through links on the Website.
The following Privacy Notice (“Notice”) sets out how we collect and use your information, the rights you have in relation to your information and the legal basis upon which we rely on to process you information. We reserve the right to modify this Notice from time to time. This Notice does not apply to companies or entities not owned or controlled by us, or to people not employed or managed by us.
We comply with the PDPO. You may wish to visit the official website of the Office of the Privacy Commissioner – https://www.pcpd.org.hk for more information about this Ordinance.
2. Scope of this Notice
This Notice applies in the following circumstances:-
- When you visit our Website and other associated pages on our Website;
- When you complete application forms on various sections of our Website;
- When you subscribe to our mailing lists to receive publications and other marketing emails or use our other online services or attend events hosted by us (including virtual events organized by us and hosted on third party platforms);
- When you apply to us for positions for employment or internships;
- When you make enquiries in relation to seeking our service;
- When we conduct open source searches on you in connection with our business development or business acceptance processes;
- When you are a potential client, a client or associated with our client(s) in the capacity of director, officer, employee, other staff member, authorized representative or other agents;
- In the course of providing legal services to you or the organization you work for;
- When you or the organization you work for are a counterparty of one or more of our clients;
- In the course of recruitment and business intake procedures;
- In the course of managing our business activities;
- When you are an alumnus of the firm;
- As and when required by law.
3. Information Collection
Information relates directly or indirectly to you and from which your identity can be ascertained may be collected through your access to this Website, by either your voluntary submission (e.g. your e-mail enquiry to us) or routine technical means (e.g. our server’s identification of your IP address). Personal information about you may also be collected from other sources including our clients (and their authorized representatives) and/or their counterparties. Information that we collect may include the following:-
- Identity related information
- The type of information we may collect includes name, contact numbers, e-mail address, postal and residential address, business address, gender, occupation, nationality and special information such as marital status, ethnicity, health-related information, and documents in order to ascertain such information.
- Business details
- The type of information we may collect includes your business interests, purpose of your business transactions, work permits, information regarding your business associates (such as affiliated companies, partnerships, directors, shareholders, authorized representatives).
- Recruitment related information
- The type of information we may collect includes your current and former employment, educational and professional qualification background, business interests, work permits/visa, employment references, information obtained from recruitment agencies and your background check for criminal records (if any).
- Billing details
- The type of information we may collect includes bank account details, billing address, information required for processing payments, source of funds, etc.
- Information for compliance
- The type of information we may collect includes all such information as required by law from time to time particularly information in relation to your identity and all information required for fulfilling obligations under the Anti-Money Laundering and Counter-Terrorist Financial Ordinance (Cap. 615)
- Publicly available information
- The type of information we may collect includes information about you that is publicly available including but not limited to information from third parties such as government agencies, regulatory bodies, information service providers, credit reporting agencies and social media platforms.
4. Use of Your Personal Information
We will only use your personal information if and to the extent that applicable law allows. We will therefore only use your personal information collected for any of the followings:-
- To fulfill the purposes identified at the time of collection;
- To communicate with you in response to your enquiries, comments and suggestions;
- To contact you/your representatives otherwise when necessary;
- To improve our relations with our clients and prospective clients by contacting appropriate individuals with relevant information;
- To serve our legitimate interests or a third party’s legitimate interests. Legitimate interests include using your information:
- For carrying out our business intake procedures;
- For providing legal services or advice to you;
- For promoting our business;
- For the functioning of our business and its operation;
- For reasons required by applicable law; and
- For development and improvement of the services we provide.
- To be provided to affiliated firms or third parties performing services for us solely for our use and benefit according to this Notice;
- To improve the content of this Website and related services and other analysis assisting our improvement in this Website and general marketing and business development activities;
- To customize the content and/or layout of this Website;
- To be provided to our website developer, and other similar services providers and their affiliates for the sole purposes of developing, hosting, managing, operating and supporting this Website, and maintaining our security system;
- To protect persons or property, or to establish or exercise our legal rights or defend against legal claims, including to comply with anti-money laundering obligations, as permitted or required by the relevant laws and regulations or as requested by the relevant government authorities;
- Where you have given your consent where necessary; and/or
- Where you have already made the information public.
Your name and contact details may be used for promoting our business. You have the right to ask us, at any time, not to use your personal data for marketing purposes. If you wish to be excluded from our list of communication for marketing purposes, please send an email stating this to firstname.lastname@example.org and we shall respect your wish.
We always request our website developer, and other similar services providers and their affiliates to protect your privacy and not disclose your personal information to third party marketers that are not associated with this Website, nor are they permitted to use your personal information for their own marketing or promotional purposes.
Save as mentioned above, we do not otherwise disclose or sell your personal information, or information identifying you or your visits to this Website to any third parties unless you give us prior consent.
5. Retention of Your Personal Information
We will retain your personal information in accordance with law and only for so long as is necessary for fulfilling the any of the above purposes or for compliance with legal, regulatory, accounting and/or record-keeping requirements. Thereafter, your personal information will be erased.
We take appropriate technical and organizational measures to ensure your personal information is not subject to unauthorized access or use, processing, modification, loss or disclosure. Your personal data shall be used and disclosed only in accordance with our Privacy Notice. However, no security system can be guaranteed to be totally secure. Therefore, while we try to protect your personal information as far as possible, we cannot ensure or warrant the security of any information you transmit to us and you do so at your own risk. You are responsible for your computer security at all times.
This Website may contain links to and from other websites. If you follow any such link, these websites have their own privacy policies and we do not accept any responsibility or liability for these policies or websites. Please check these policies before submitting any personal information to these websites.
7. Your Rights
In accordance with the terms of the PDPO and guidelines issued pursuant thereto, either you or any relevant person on your behalf are entitled to, at any time:-
- Make a request to ascertain whether we hold personal data about you and may request access to such data;
- Request us to correct any data relating to you which is inaccurate;
- Request us to cease using your personal information for marketing purposes.
We reserve the right to reasonably refuse to comply with data access or correction requests where permitted or required by law.
If you need further information or have any questions or requests regarding our Privacy Notice, please address your questions or requests at this email: email@example.com or post at our office address.
Ling & Lawyers
Room 903, 9/F
Yip Fung Building
2-18 D’Aguilar Street
Central, Hong Kong
Attn. Administration Department