Startup shall fully comply with its obligations under the requirements of the Personal Data (Privacy) Ordinance (Cap.486) and Personal Data (Privacy)(Amendment) Ordinance (collectively the “Ordinance”) of the Hong Kong Special Administrative Region of the People’s Republic of China. Startup shall at all times respect the confidentiality of the endeavor to keep safe any and all Personal Data collected and/or stored and/or transmitted and/or used for or on behalf of Startup.
1. Collection of Personal Data
a) For the purpose of carrying on Startup’s business, you may be requested to provide your Personal Data when you register for a membership, when you purchase a product or use our services at Startup, when you submit any comments or feedback to us, when we ask you to verify your identity.
b) We will ask you to provide your Personal Data, including, name, contact number, email address, gender, date of birth, age and the region/country where you normally reside.
c) We will collect Personal Data on a lawful, open and fair basis.
2. Purpose for Collection of Personal Data
Startup will collect and may use your personal data for the following purposes:
a) The provision of Startup’s products and/or services to you at our branches;
b) Carrying out your instructions or responding to your enquiry
c) Forming part of Startup’s customer data base necessary for the operations carried on by us;
d) Transferring or sharing your Personal Data with other Startup branches operated by our affiliates in other countries and territories (Branches refer to Startup branches (“ branches”)for the purposes of carrying out (a) (b) and (C) above in this section;
e) General security reasons; and
f) Any purposes related to and/or for the furtherance of (a)to (e) above.
Without your consent, we shall not use your Personal Data for purposes other than those specified above.
Startup will take all practicable steps to ensure that Personal Data collected is accurate. Please endeavor to provide Startup with accurate Personal Data upon subscription of Startup’s services and where there are any changes to your Personal Data, please inform us as soon as possible.
4. Personal Data Sharing, Transfer and Disclosure
All Personal Data held by Startup will be kept confidential but Startup may, where sharing, transfer or 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 person or company who is acting on behalf of Startup as agent in respect of the purpose or a directly related purpose for which the data was provided.
b) Personal data may also be disclosed to any person or persons pursuant to any statute or as required by any court of law in Hong Kong, provided such person or persons are able to prove the required right/authority to access such information.
c) We may transfer or share your Personal Data to/with other branches operated by our affiliates
d) We will not sell your personal data to any person
e) We will not share, transfer or disclose your personal data to/with any person or company, including Startup’s affiliates. For direct marketing purposes.
5. Access and Correction
We will take reasonable steps to verify your identity before granting access or permitting corrections to your Personal Data. We will endeavor to respond within 40 days of your request in compliance with the Ordinance. We will charge a reasonable fee to cover our administrative costs when you request for access or correction, reason(s) will be given. You may object to our reason(s) for our refusal to grant you access or correction.
We strive to ensure that your Personal Data will be protected against unauthorized or accidental access, processing, erasing or other use, We maintain this commitment to data security by implementing appropriate physical, electronic and managerial measures to safeguard and secure your Personal Data.
7. Retention of Personal Data