Collection of Personal Data Statement and Privacy Policy
(“Personal Data Privacy Statement”)
Lee in action ( “Our Company”) respects your privacy and will comply with the requirements of the Personal Data (Privacy) Ordinance (Chapter 486 of the Laws of Hong Kong) (the “Ordinance”) to collect, use, and process your personal data and “personal data” in this Personal Data Privacy Statement has the same meaning as “personal data” in the Ordinance. You shall read this Personal Data Privacy Statement carefully so as to ensure that you fully and clearly understand the contents herein.
Collection of Personal Data Statement
1. Our Company may collect your personal data in several ways whenever Our Company provides the Services to you, The Services shall mean the service platform(s) (including Our website, https:/hkaccount.ing (“Our Website”)), application(s) (including mobile device application), membership registration/registered user, personalization services, classified post, promotion, games and/or any other products/services provided by Our Company.
2. Whenever you use the Services, which may include access to Our Website, use software or submission of contents via Our Website, you are deemed to have read the Personal Data Privacy Statement and agree to allow Our Company to collect, use and/or process your personal data in accordance with the Personal Data Privacy Statement.
3. Our Company will collect your personal data which includes your name, working company, email address, date of birth, gender, age, occupation, contact phone number, postal address, personal income, education level or credit card information.
4. For security reason and Services’ need, Our Company will collect some other information from you, such as the place of residence and working company, nickname, login password, answers to two questions for login password recovery, and personal assets. In addition, Our Website will, by means of Cookie, automatically receive and record general information about users and internet protocol address from your computer and browser.
5. Purpose of collection and use of personal data
6. Our company will collect your personal data for the following purposes:
6.1. provision and administration of the Services to you;
6.2. processing the application for membership or registered user and administration of the members’ /registered users’ account;
6.3. identifying and verifying your identity to ensure that you have the right to use the Services;
6.4. conducting follow-up and handling all the matters in relation to the Services, such as contact, enquiry and complaint;
6.5. carrying out promotion and providing you with new information and other information (including notifying you Our Company’s goods/services);
6.6. conducting survey, data analysis, or carrying out research to enable Our Company to understand your or other users’ needs, upgrading or improving the quality of Services, business development, and customization of the Services;
6.7. investigation of complaints or claims;
6.8. registration and administration of the promotional activities, games or competition conducted by Our Company alone or together with other third parties;
6.9. consolidation of other information to carrying out analysis for exploring business opportunities or introducing the Services to any potential business partner, advertiser, or third party and all the related purposes;
6.10. prevention and detection of crime and for disclosure or assistance in accordance with the legal (such as court order) or regulatory authority requirement;
6.11. all other matters in relation to the daily operation of Our Company;
6.12. collection and preparing statistics the users’ data via Cookie for administration and improvement of the Services; and
6.13. protection of Our Company’s interest and for all the matters in relation to the above-mentioned purposes.
7. Whenever you are requested by Our Company to provide your personal data, you have the right to decide as to whether you should provide your personal data to Our Company but are not obliged to do so. If you do not provide Our Company with the requested information or if the information provided by you is inadequate or inaccurate, Our Company may not be able to provide you with the Services and you may be unable to enjoy the Services.
8. Disclosure/transfer of Personal Data
9. Our Company will not sell your personal data to any third party..
10. Our Company will also disclose or transfer your personal data under the following circumstances:
10.1. Business Parties and Sponsors
The promotions, games or other activities (the “activity”) organized by Our Company may be co-organized or sponsored by the third party (the “Business Partners”). Our Company may disclose or transfer your personal data to the Business Partners for any of the stated purposes and your personal data may be retained for such period as may be necessary for verification and record purposes, but you will be notified in advance, and you shall refer to the specific Terms and Conditions for that particular activity. If you do not want your personal data be disclosed or transferred to the Business Partners, you shall not participate in the activity.
In addition, in some activities, Our Company may ask you whether you wish to receive the Business Partners’ information (including but not limited to promotional materials), and if you have signified your agreement, Our Company will disclose or transfer your personal data to the Business Partners to enable them to satisfy your demand. However, as the Business Partners have their own collection of personal data and privacy policy (the “Business Partners’ Privacy Policy”), you should read over the Business Partners’ Privacy Policy before making decision. In any event, Our Company shall have no liability or responsibility in relation to the use of your personal data by the Business Partners.
10.2. Potential business partners or sponsors
Our Company may disclose or transfer the statistic results about you and other users (which will not include your personal data sufficient for identification) to the potential business partner or sponsor or other third party, for exploring business opportunities or business development.
10.3. Others
If someone may have committed breaches of Our Company’s “Terms and Conditions of Use”, or if interests of Our Company may have been prejudiced or impeded, or if someone may have been suffered loss by reason of your or other user’s improper act (whether with or without intent) (such as infringement of other party’s intellectual property by you) or you may have been involving in unlawful act, and Our Company is of the opinion that disclosure of your personal data will contribute to the identification, contact or instituting any legal action against you or other users, Our Company will disclose or transfer your personal data to the related person. In addition, Our Company will disclose your personal data according to the requirement of regulatory authority to which Our Company is subject, or legal requirement.
11. Access to and correction of personal data
You have the right to access to and request for correction of your personal data in accordance with the provisions of the Ordinance. Any request shall be made in writing to Our Company at cs@hkaccount.ing
12. Direct Marketing
Our Company may use your personal data for direct marketing, but Our Company will not use your personal data for direct marketing unless and until you consents (or indicate that you have no objection) thereto.
However, if you do not wish Our Company to use your personal data for direct marketing, please make written request by email to cs@hkaccount.ing
13. Security
Our Company will keep your personal data confidential.
Your membership account or other registered account are password-protected and you are solely responsible for the security of your login password and the information contained in the account. Our Company will not, without your prior consent, ask for your login password via telephone or email, and you should not disclose your login password to any third party. In addition, you are reminded that you shall sign out of your account and close the window of the browser after using the Services so as to prevent others from having access to your personal data.
14. Privacy Policy
Our Company shall comply with the requirements under the Ordinance, and shall endeavour to maintain the security and confidentiality of your personal data.
However, if you are under 18 (or person under disability incapable), you shall not provide your personal data to Our Company unless and until you have obtained your parent’s or guardian’s consent, and as Our Company will collect the users’ access information via Cookie, and you can choose not to accept Cookie, but such act may affect certain functioning of Our Website.