(First publishing date on 24 September 2015)
(Last updated on 24 September 2015)
By accessing and/or using the Website, you are accepting the Terms and Conditions of Use and this Policy. If you do not agree to the provisions of the Terms and Conditions of Use and/or this Policy, please do not continue your access to or use of the Website.
We reserve the right to change the provisions of this Policy at any time. We will alert you that changes have been made by indicating on this Policy the date that it was last updated and publishing the updated version of this Policy on the Website. You should review this Policy from time to time and each time you access the Website to check if this Policy has been updated. Your continued access and/or use of the Website following the posting of changes to this Policy will mean that you have accepted and agreed to those changes. If you do not agree, you should stop accessing or using the Website. If you have any question about this Policy, please contact us at firstname.lastname@example.org or LUI Che Woo Prize Limited,1801, K. Wah Centre, 191 Java Road, North Point, Hong Kong.
This Policy is issued in English and Chinese. In the event of any discrepancy or inconsistency between the two versions, the English version shall prevail.
We will only collect and use your personal data for the purposes set out in this Policy.
- What kind of personal data is collected?
Two basic types of information may be collected from you through the Website, namely, “Personal Data” and “Non-Personal Data”.
1.1 Personal Data
“Personal Data” refers to any information which can individually identify you or any individual, such as, but not limited to, name, e-mail address, telephone number, postal address.
1.2 Non-Personal Data
“Non-Personal Data” refers to any information which cannot individually identify you and includes “aggregate” and/or automatic information, which is data collected about the use of the Website or about a group/category of users of the Website from which identities of individuals or other individually identifiable information (if any) has been removed.
When you access and use the Website, we may keep an activity log that does not identify you individually and cannot be used to identify the identity of any particular visitor of the Website. Generally, we collect and use Non-Personal Data including but not limited to the following:-
- Device information about your mobile or other electronic device that you use to access the Website, which may include the IP address of your electronic device, the operating system of your electronic device, the type and configuration of the Internet browser on your electronic device, geo-location information and other unique device identifiers of the electronic device used to access the Website, browsing preferences such as language setting and font size, etc;
- Information about your access and use of the Website, including the number of new or returning visits, statistics on the pages visited and referred, reading history of the pages viewed, “traffic data” such as time of access and date of access, etc.
- We may collect, use and share these Non-Personal Data for customizing, enhancing and optimizing the quality and users’ browsing experience of the Website, and for maintaining and improving the Website (including but not limited to determining optimal screen resolution, language and font settings, etc).
For the avoidance of doubt, this Policy in no way restricts or limits our collection, use and provision of Non-Personal Data.
1.3 IP address and geo-location information
When you access the Website, we and/or any third party service provider providing website statistics and analytical services or other services for the Website may use GPS technology (or other technology) to determine and collect information about the current location and the IP address of your electronic device. Such geo-location and IP address information is a type of Non-Personal Data that is collected anonymously in a form that does not personally identify you.
We collect, use, and may share geo-location information and the IP address of your electronic device for customizing, providing, optimizing, maintaining and improving the quality and users’ browsing experience of the Website. When this type of Non-Personal Data is shared with the aforesaid third party service providers for the above purposes, the data do not individually identify you, and the other parties do not have access to your personally identifiable data.
Most browsers are initially set up to accept cookies. You can manage and adjust your cookies setting by changing the browser setting for your electronic device. However, if you choose to decline or disable cookies on your electronic device, some features and functionality of the Website may not work properly.
- How do we use your data?
We may use your Personal Data and Non-Personal Data in the following ways:
- Monitor, maintain, customize or improve the contents, security, quality and/or users’ experience of the Website, as well as the security of our servers and network;
- Manage and facilitate our handling of your inquiries and/or communications with us;
- Detect, investigate and prevent activities that may violate our policies or be illegal;
- Facilitate, compile, prepare, process, perform and generate statistics and analytical reports and analysis for the Website;
- Use for or in connection with our operation, management, administration, publicity, publication, public relations activities, provision of information to the press and public, and/or any other functions, services or activities that we may undertake (whether now or in the future) for, in relation to or otherwise in connection with the Prize and/or the Website.
- Direct marketing
We do not and will not collect, use and provide your Personal Data for direct marketing to you.
- Who do we provide your data to?
We may provide your Personal Data and/or Non-Personal Data to other third parties for various purposes as set out in further detail below. Except as expressly set forth in this Policy, we do not share, sell, transfer, provide, rent or trade your Personal Data with third parties unless we have obtained your express voluntary consent in accordance with the PDPO’s relevant requirements:
- We may share Non-Personal Data with third party service provider providing website statistics and analytical services and other services for the Website. When this type of Non-Personal Data is shared, those data do not individually identify you and also cannot be used to identify the identity of any particular visitor of the Website, and the other parties do not have access to your personally identifiable information;
- We may transfer any of the information described in this Policy to service providers engaged to process data on our behalf, or to provide us with services in relation to information technology support, server and database management and maintenance, website hosting, etc, or provide services or functions for or on our behalf (which may include but are not limited to publicity-related services) for or in connection with any or all of the relevant purposes as set out in this Policy and/or our operation and management of the Prize and/or the Website;
- We may transfer or assign any or all of the information described in this Policy to any third parties as a result of a merger, acquisition, consolidation, transfer of assets, change of control, re-organisation of our company/operation, liquidation, or sale or dissolution of assets; or
- We may be required to disclose your Personal Data or any or all other information described in this Policy pursuant to a subpoena, court order or legal process, or to comply with any applicable laws or regulations, or lawful request from government authority, which may be without notice to you.
- Data security
The Website and our servers have incorporated reasonable safeguards to protect the security, integrity, completeness, accuracy and privacy of the Personal Data (if any) that we may collect and we have put in place reasonable precautions and measures to protect such information from unauthorized access, alteration, disclosure, loss, and misuse. However, while we try our best to safeguard your Personal Data (if any) once we receive it, no security or encryption method can be guaranteed to protect information from hackers or human error, and no transmission of data over the Internet or any other public network can be guaranteed to be 100% secure. We shall not be liable to you for any unauthorized access, alteration, disclosure, loss, and misuse to your Personal Data, and we shall not be held liable for any claims, loss or damage whatsoever howsoever resulting from any such unauthorized activity and/or any security breach not caused by our negligence or outside our control.
- Storage or processing of data
The information (if any) that we collect through the Website may be stored or processed on computers or servers located in any country. By providing us with your Personal Data or by accessing and using the Website, you understand, agree and consent to the transfer of your Personal Data outside Hong Kong to our facilities or data processors located outside of Hong Kong. The personal data protection laws of the other countries might not be as comprehensive as those in Hong Kong, but we will take all reasonable steps to ensure the protection of your privacy and will only collect and use your Personal Data for the purposes which are set out in this Policy.
- Your obligations to keep your electronic device and access secure
You are entirely responsible for any and all activities which occur when you access and use the Website and for keeping your electronic device and access secure. We shall not be held liable for any claims, loss or damage whatsoever howsoever resulting from any unauthorized access or use of the Website and/or any security breach not caused by our negligence or outside our control.
- Links to other website(s) or other online platform(s)
- Access to and update of Personal Data
You have the right to know whether we hold your Personal Data, what type of Personal Data is held, and request access to, and correction of, any of your Personal Data held by us. If you have any such inquiries or wish to have access to your Personal Data and/or to correct any Personal Data relating to you that is inaccurate, you may send such inquiries or requests to email@example.com or LUI Che Woo Prize Limited, 1801, K. Wah Centre, 191 Java Road, North Point, Hong Kong.
- Controlling your Personal Data
You may always opt-out of receiving communications from us. We will provide you with the opportunity to opt-out of receiving communications at the point where we request information from you or you can send us your opt-out request at firstname.lastname@example.org or LUI Che Woo Prize Limited, 1801, K. Wah Centre, 191 Java Road, North Point, Hong Kong.