Alphalion-Privacy Statement

LEGAL

Privacy Statement

SCHEDULE 1: PRIVACY POLICY STATEMENT

Personal Data (Privacy) Ordinance

Alphalion complies with the Personal Data (Privacy) Ordinance ('Ordinance'). You may wish to visit the official website of the Office of the Privacy Commission http://www.pco.org.hk for more information about this Ordinance.

Your personal data

It is our policy to protect the privacy of users of the Website. We may, however, collect a very limited amount of your personal data (by 'personal data', we mean information about you or which can be used to ascertain your identity). For example, we may collect some information about you when you visit the Website because your internet provider address needs to be recognised by our server. You will also be invited to provide some information about yourself on various pages of the Website. We do not use 'cookies'.

Collection and use of your personal data

Any personal data collected from you on the Website will only be used for the specific purposes mentioned at the time of collection or for purposes directly related to those specific purposes and/or in Alphalion' Personal Information Collection Statement.

Direct marketing

We would like to use your name and contact details to send you marketing materials about our services and/or related products but we must obtain the consent (or an indication of no objection) of people who become our clients or staff before we can do so. If you do not want to receive our marketing materials, please send an email stating this to marketing@alphaliongroup.com. More information about this can be found in our Personal Information Collection Statement (Schedule 2).

Retention of your personal data

We will retain your personal data only for so long as is necessary for fulfilling the purpose for which they were collected. After that time, your data will be erased or discarded.

Disclosure

Your personal data will generally be kept confidential and will not be disclosed to any other person without your consent. However, your data will be used (and disclosed) to third parties for the purposes for which they were collected. Your personal data may also be disclosed where we are required to do so by law. Please also refer to our Personal Information Collection Statement (Schedule 2) as appropriate, for details.

Security

We have installed security systems to ensure your personal data are not subject to unauthorised access.

Your right of access to and to correct personal data

You are entitled, in accordance with the Ordinance, to check whether we hold data about you and to have access to those data. If any of these data are incorrect or inaccurate, you have the right to correct or update them. Requests for access to or to correct personal data should be addressed to Client Services Team, Alphalion Technology Limited. In accordance with the Ordinance, we are entitled to charge a reasonable fee for processing any data access or correction requests.

SCHEDULE 2: PERSONAL INFORMATION COLLECTION STATEMENT

Section A: For Clients

It is often necessary for individual clients or (where clients are businesses, incorporated or otherwise) their individual representatives (including without limitation directors, other officers, employees and staff members of client businesses) (in this statement these individual representatives will, for the sake of brevity, also be referred to generally as “clients” and, in paragraph 4.7(b) below, as "Representatives") to supply Alphalion with data about themselves in connection with Alphalion’ provision of Services to those clients. These data may include copies, and other details, of identity documents, proof of address, other contact details, and proof of authority to engage the services of Alphalion.

Failure to supply such data may result in Alphalion being unable to provide clients with the its services.

It is also the case that Alphalion collects data from clients in the ordinary course of the vendor-client relationship on an ongoing basis.

Purposes of collection and use of personal data:

4.1

The purposes for which personal data relating to a client may be used are as follows:

4.1.1.

Obligatory purposes: where a client does not want Alphalion to use his personal data for any of the purposes listed in paragraphs 4.1.2 below (inclusive), Alphalion will not be able to provide the Services requested

4.1.2.

Other general business purposes, including:

4.1.2.1.

the provision of services to the client in accordance with terms of business or services agreement with the client and as Alphalion may otherwise deem appropriate or necessary;

4.1.2.2.

designing services or related products for clients’ use;

4.1.2.3.

collection of outstanding fees from clients;

4.1.2.4.

meeting the requirements to conduct client identification and verification and to make disclosure under the requirements of any law, guideline, code of practice or practice direction binding on, or applicable to, Alphalion or any of its branches or associated firms or offices including, but not limited to, any such law, guideline, code or practice direction relating to anti-money laundering and anti-terrorism;

4.1.2.5.

purposes specifically provided for in any particular service offered by Alphalion;

4.1.2.6.

purposes directly related to any of the above;

4.1.3.

Marketing: the client's name and contact details (including but not limited to office address, telephone number and email address) provided by the client to Alphalion will be used for marketing Alphalion' own services and/or related products.

4.2.

If a client does not want Alphalion to use his personal data for the purposes mentioned in paragraph 4.7 above, he may write to or email the officer named at the end of this statement, indicating his decision and/or return a copy of this statement to that officer.

4.3.

IMPORTANT NOTES about Alphalion marketing:

4.3.1.

Clients may at any time send a notice to Alphalion requesting Alphalion to cease using their personal data for these purposes and Alphalion will honour such requests promptly; and

4.3.2.

All marketing in relation to Alphalion services and related products to Representatives is sent to them in their official capacity as representatives of the client business for whom they work or represent and not in their individual capacity.

Exceptions to confidentiality

5.1.

any other branch or associated firm or office of Alphalion;

5.1.2.

a government agency such as the Hong Kong Police, the Hong Kong Customs and Excise Service, the Hong Kong Immigration Service and the Independent Commission against Corruption, if Alphalion knows or suspects that any person is engaged in drug trafficking, terrorism or any other serious crime or handling the proceeds of crime or that any property constitutes terrorist property; in this case, the obligation to report to the authorities may override Alphalion' confidentiality obligations;

5.1.3.

any financial institution, business or professional firm with which the client has or proposes to have dealings related to the services being provided to the client by Alphalion;

5.1.4.

any actual or proposed assignee of Alphalion or transferee of Alphalion’ rights in respect of the client;

5.1.5.

if a client is ever in default of payment of any fees or other moneys to Alphalion or otherwise, debt collection agencies;

5.1.6.

to third party service providers which provide administrative, technology, marketing or other services to Alphalion in relation to its business operations.

5.2.

1.1. Alphalion will not transfer data relating to a client to a third person for that person's marketing activities.

Under and in accordance with the terms of the Personal Data (Privacy) Ordinance (“PDPO”) and guidelines issued pursuant thereto, any individual may:

6.1.

check whether Alphalion holds data about him/her and may request access to such data;

6.2.

check whether Alphalion holds data about him/her and may request access to such data;

6.3.

request Alphalion to specify its policies and practices in relation to data and to be informed of the kind of personal data held by Alphalion;

6.4.

request Alphalion to specify its policies and practices in relation to data and to be informed of the kind of personal data held by Alphalion;

n accordance with the terms of the PDPO, Alphalion has the right to charge a reasonable fee for the processing of any data access request.

Requests:

8.1.

for access to data or correction of data;

8.2.

for information regarding policies and practices and kinds of data held are to be addressed IN WRITING to:

Client Services Team, Alphalion Technology Limited

Section B: For Staff

For people intending on applying for jobs within Alphalion you should aware that it is necessary for staff members ('data subjects') to supply Alphalion with data about themselves and sometimes also their family members from time to time in connection with their employment.

Failure to supply such data will result in Alphalion being unable to operate its practice properly and may affect a data subject's employment prospects with Alphalion and even result in dismissal.

The purposes for which data relating to data subjects are to be used are as follows:

3.1.

identification and determination of eligibility for employment in Hong Kong generally and qualifications relevant to data subject's employment with Alphalion in particular;

3.2.

assessing work performance, attendance and disciplinary record;

3.3.

reviewing salaries, bonuses and other benefits;

3.4.

consideration of eligibility for staff loans;

3.5.

providing employee references;

3.6.

disclosure to immigration authorities - in relation to employment visa, where required;

3.7.

disclosure to tax authorities in the ordinary course of business;

3.8.

all other matters relating to employment of a data subject.

Data held by Alphalion relating to data subjects will be kept confidential but Alphalion is authorised to provide such information to:

4.1.

any person when Alphalion is compelled to make disclosure under the requirements of any law binding on it or any of its branches, including, without limitation, tax authorities;

4.2.

any person with the express or implied consent of the data subject;

4.3.

any person where the interests of Alphalion require disclosure;

4.4.

any person where the public interest requires disclosure;

4.5.

any agent, contractor, or third party service provider who provides administrative, telecommunications, computer or other services to Alphalion in connection with the operation of its practice;

4.6.

any other person under a duty of confidentiality to Alphalion including member of Alphalion and other associated firms and related business which has undertaken to keep such information confidential;

4.7.

persons seeking employee reference;

4.8.

Personnel Department staff of Alphalion and supervisors of the data subject during the course of his/her employment; and

4.9.

pensions or insurance companies with whom Alphalion has arranged benefits entitlement/coverage for staff.

Under and in accordance with the terms of the Personal Data (Privacy) Ordinance (the 'Ordinance') any individual:

5.1.

has the right to check whether Alphalion holds data about him/her and the right of access to such data;

5.2.

has the right to require Alphalion to correct any data relating to him/her which is inaccurate;

5.3.

has the right to ascertain Alphalion's policies and practices in relation to data and to be informed of the kind of personal data held by Alphalion.

In accordance with the terms of the Ordinance, Alphalion has the right to charge a fee for the processing of any data access request.

The person to whom requests for access to data or correction of data for information regarding policies and practices and kind of data held are to be addressed to The Head of Human Resources & Administration, Alphalion Technology Limited.

If a data subject is at any time requested to supply information about members of his/her family, he/she is requested to pass a copy of this notice to the relevant family member so that he/she is aware of his/her rights under the Ordinance.