1. General

   1. This statement provides information on the policies of Laputa Technologies Limited in respect of any business and website of the Laputa Technologies (collectively "Businesses") under the Personal Data (Privacy) Ordinance (Cap.486) of Hong Kong (“Ordinance”).

   2. Terms used in this statement shall, unless otherwise specified, be construed in accordance with the Ordinance.

2. Purpose of collection of personal data

   1. The provision of any personal data by you or on your behalf to the Businesses shall be voluntary and shall be deemed to authorize our Company to collect, retain, update and use your personal data for the purpose of clause 2.2 below.

   2. The personal data provided by you or on your behalf to the Businesses from time to time as well as all other personal data related to you collected and held by our Company will be used for the following purposes: 

      • Operating daily for provision of goods, facilities and services to you;

      • Providing additional goods, facilities and services to you as they may arise from time to time;

      • Updating and verifying your identity and other information in accordance with relevant laws;

      • Marketing and direct marketing purposes, including the service or products of selected business partners, and issuing any advertising and/or marketing materials to you;

      • Conducting statistics and market research for the purpose of providing products or services to you;

      • Performing statistical analysis of your habit and behaviour in order to design suitable products and services to you;

      • Making such disclosures as may be required for any of the above purposes or by law;

      • Achieving any other lawful purposes relating to any of the aforesaid purposes; and

      • Enforcing any legal or other rights that our Company may have against you in respect of the Businesses.

   3. For the purposes stipulated in clause 2.2 above, any employee of our Company shall be entitled to inspect the personal data provided by you.

3. Use of personal data

Our Company will ensure the confidentiality of collected personal data but may provide such information to the following parties (including parties within as well as outside the Hong Kong Special Administrative Region (“Hong Kong”) for the purpose of implementing the “purpose of collection of personal data” mentioned above:

• Any agent, contractor or third party service provider who provides administrative, telecommunications, computer, or other services to the Businesses;

• Any agent authorized by the Businesses from time to time to process personal data of our customer;

• Auditors, consultants or legal adviser(s) of our Company, within as well as outside Hong Kong;

• Any other person under a duty of confidentiality to our Company; and

• Any of the actual or proposed assignees or transferees of the Businesses.

1. Duty of confidentiality

   1. Our Company shall exercise reasonable endeavours to ensure that the personal data provided by you shall be kept confidential and be placed in secure locations. Our Company shall further exercise reasonable endeavours to ensure the integrity, prudence and competence of the persons who have access to such data.

   2. In compliance with any law in Hong Kong, our Company may disclose the personal data provided by you to governmental authorities or other regulatory bodies or persons.

2. Special provisions for personal data held by our Company on the internet

   1. By assessing the Businesses through our Company's website (“Site”), you shall be deemed to agree to the terms and conditions in this statement.

   2. All reasonable efforts are made to ensure that any personal data held by our Company from time to time through the Site is stored in secure and safe storage.

3. Cookies

Cookies are small files which are stored on your computer or other electronic device when you access the Company’s website. We may collect or use “cookies” on the Site so as to:

• enable tighter security;

• enable you to complete the application process;

• personalize the Site for you;

• improve our service and understand our visitor behaviour; and

• build online profile for you.

• You may disallow “cookies” at any time on your web browser. If you disable cookies, you acknowledged that you may not able to achieve the same functionality of our website.

1. Your rights

   1. In the event that you have objections to any use of the personal data in accordance with clause 2 or any provision or disclosure of such data in accordance with clause 3 above, please inform our Company in writing. The address of our Company is stated in the relevant forms/contracts executed between you and us. Our Company shall cease the use and/or provision or disclosure of such data upon confirmation of your request.

   2. Unless you request our Company to dispose of all personal data provided by you, you acknowledge that we shall retain all such personal data and may continue to deliver to you marketing information.

2. Access and correction request

   1. You have the right to request access to and correction of your personal data in accordance with the Ordinance.

   2. In the event that you intend to correct any personal data, please inform our Company in writing so that our Company shall be able to make the amendments accordingly.

   3. Enquiries concerning the personal data collected, including access and corrections, should be addressed to the address stated in the relevant forms/contracts executed between you and our Company or any other address from time to time stipulated by the Businesses.

   4. In accordance with the terms of the Ordinance, our Company has the right to charge a reasonable fee for the processing of any data access request. You agree to pay such fees.

3. Use of personal data in Direct Marketing

The Business intends to use a customer's personal data in direct marketing and may not so use the data unless our Company has received the customer's consent (which includes an indication of no objection) to such intended use. In this connection, please note that:

1. the name, contact details, products and services portfolio information, transaction pattern and behaviour, consumption preference, financial background and demographic data of the customer held by the Businesses from time to time may be used by the Businesses in direct marketing;

2. The Businesses also intend to provide the above personal data to all for use by them or it in marketing those goods, facilities, services and other marketing subjects, and the Businesses may not so provide the data unless our Company has received the customer's written consent (which includes an indication of no objection) to the intended provision. If the customer does not wish the Businesses to use or provide to any other persons his personal data for use in direct marketing as described above, the customer may exercise his opt-out right by notifying our Company, in which event the Businesses must, without charge to the customer, cease to use or provide to other persons the customer's personal data for use in direct marketing. The customer may provide his consent to the Businesses' using or providing to other person his personal data for use in direct marketing as described above by notifying the Data Protection Officer of the Businesses, whose contact details are set out below, or through such other channel which the customer may be advised of when providing personal data to the Businesses.

1. Data protection officer of the Businesses

The person to whom requests for access to data or correction of data or for information regarding our Company's privacy policies and practices and kinds of data held and for any other communications hereinabove described are to be addressed is as follows:

      The Data Protection Officer 

       Address [8/F, DCH Building, 20 Kai Cheung Road, Kowloon Bay, Hong Kong]

       Tel. [2768 3474] Fax. [2753 6266] E-mail [marketing@laputatech.com]