Last updated: 4 November 2020
1. What information we collect about you
HKBN JOS collects your information to operate effectively and provide you with the best experiences with our services. The specific kinds of information collected will depend on the context of your interaction with HKBN JOS, and the services you use. The following are examples of the information that may be collected:
- Contact information (such as your name, phone number, company name, industry, postal address, email address);
- Copies of your correspondence if you contact us;
- Your interests and preferences;
- Information related to your use and interaction with our website.
We collect this information in a variety of ways, including information you give to us.
We receive and store information you enter on our website or give us in any other way:
- Automatic Information
When you use or interact with our website and/or use any apps that we may make available on our website, we receive and store information generated by your activity and information automatically collected from your browser or mobile device. For example, like many websites, we obtain certain information when your web browser accesses our website including your IP address, browser type, operating system, mobile network data, pages viewed and access times. This information helps us to communicate with our customers and better understand them.
Our website may pass a “cookie” (a string of information that is sent by a website to reside in your computer’s hard drive and/or temporarily in your computer’s memory). The purpose of a cookie is to tell the web server that you have returned to a particular page, to retain log-in information or to remember preferences and enhance your experience on our website. We may allow third parties to set cookies through our website in order to help us manage and analyse the performance of our website. You may set your browser to decline cookies. If you do so, you may not be able to fully experience some interactive features of our website.
- Information from Other Sources
We may receive information about you from other sources, such as public databases, joint marketing partners, and other third parties. This may include information from your credit card, and other partners.
- Age Limitations
HKBN JOS does not knowingly collect personally identifiable information from our websites from any person under the age of 16.
2. How we use your information
HKBN JOS collects your information to better manage your relationship with us and serve you on any of the following and for other purposes that shall be agreed between you and us. HKBN JOS may collect, use, and disclose the information it collects for a variety of reasons, including for the following purposes:
- Marketing and Promotions. To communicate news and promotions to you relating to HKBN JOS related products and services and other products and services we think may be of interest to you, and to operate sweepstakes, contests, or other marketing or promotional activities (you can opt out anytime by updating us as to your preference).
- Internal Business Purposes. For our internal business purposes, such as data analysis, audits, developing new products, enhancing the website, improving our services, identifying usage trends and visiting patterns, determining the effectiveness of our promotions, and meeting contractual obligations.
- Response to Inquiries. We may process information contained in or relating to any communication that you send to us (“correspondence data”). The correspondence data may include the communication content and metadata associated with the communication. The correspondence data may be processed for the purposes of communicating with you and record-keeping.
- Administrative and Other Communications. To send you important information regarding our website, changes to our terms, conditions, and policies, or other administrative information.
- Our Legal Duties. To comply with legal and regulatory requirements or demands in accordance with applicable law, a court order, subpoena, or other legal process.
- Additional Uses. We may also use your data in other ways as described to you when you provide such information to us.
The legal grounds for processing your personal information consists of one or more of the following: (i) your consent, and/or (ii) providing the services you have requested, and/or (iii) compliance with applicable laws, regulations, court orders or other legal process.
3. Sharing information
In order to provide you with the best experience, your personal information may be shared with the following parties insofar as reasonably necessary for the purposes, and on the legal grounds, set out in this policy:
- to third parties not affiliated with HKBN JOS when we have your consent to do so;
- to our marketing and advertising partners to provide you with more-relevant ads on our site and to encourage you to return to our site;
- to third parties not affiliated with HKBN JOS if we have a good-faith belief that it is reasonably necessary to: (1) meet any applicable law, regulation, legal process or enforceable governmental request; (2) enforce applicable terms of service, including investigation of potential violations; (3) detect, prevent, or otherwise address fraud, security or technical issues;
- to any third parties to the extent necessary with respect to a sale of all or part of our business operations or assets; and
- to any courts, law enforcement bodies or governmental authorities in order to comply with our legal obligations and respond to any claims asserted against us. We will only disclose information to the extent we are legally obligated to.
4. Information transfer
We will take reasonable steps, such as entering into data transfer agreements based on the European Commission model clauses, or requiring compliance with the EU-US Privacy Shield to ensure that while your personal information is within our control, we will handle your personal information using reasonable security and confidentiality procedures to keep your personal information secure and confidential.
5. Information security
We implement reasonable administrative, organisational and technical safeguards and security measures to protect personal information within our control from unauthorised access, acquisition, disclosure, destruction or alteration, accidental loss, misuse or damage. We regularly review and monitor such safeguards and security measures.
However, no security measures can ever be completely secure, therefore we cannot guarantee that these measures will stop any users who try to get around the privacy or security settings on the HKBN JOS website through unforeseen and/or illegal means.
In the event that we believe that the security of your personal information in our possession or control may have been compromised or could be at risk, we will seek to notify you as promptly as possible. If we have your e-mail address, we may notify you by e-mail.
6. How long the information will be kept
To the extent permissible by applicable law, we will retain your personal information for such periods as necessary in order to satisfy or to fulfill the following:
- the purposes for which that personal information was provided,
- an identifiable and ongoing business need, including record keeping,
- a specific legal or regulatory requirement, and/or
- a requirement to retain records that may be relevant to any notified regulatory investigations or active legal proceedings.
Where there is no sufficient justification to retain such personal information, such personal information will be safely and securely deleted, disposed of, anonymised and/or blocked.
7. Your rights
Our Data Protection Officer will be happy to answer any concerns or queries you may have relating to the use or storage of your personal data. Your principal rights hereinunder are:
- the right to access your personal data;
- the right to rectification of your personal data;
- the right to erasure of any or all of your personal data;
- the right to restrict processing of your personal data;
- the right to object to processing of your personal data;
- the right to data portability (means, you may ask us to transfer your personal data to a third party);
- the right to complain to a supervisory authority; and
- the right to withdraw your consent to our use of your personal data.
You may exercise any of these rights in relation to your personal data by contacting us anytime via email at email@example.com or by telephone +65 6551 9611. You may also request access to your Personal Information, withdraw your consent to our use or disclosure of your Personal Information, or update or correct your Personal Information through the above contact.
Note that the withdrawal of your consent does not affect the lawfulness of any processing of your information by us before the withdrawal of your consent.
8. Linked website
Effective Date: 31 December, 2019
Last updated: 4 November 2020