(a) We will collect personal information about you from a variety of sources, including information we collect from you directly, for example when you sign up to receive our Services, when you contact us and when you enter into agreements with us.
(b) Note that we may be required by law to collect certain personal information about you, or as a consequence of any contractual relationship we have with you. Failure to provide this information may prevent or delay the fulfilment of these obligations. We will inform you at the time your information is collected whether certain data is compulsory and the consequences of the failure to provide such data.
(c) The categories of information that we collect directly from you, or that we generate through entering into agreements with and providing services to you, are:
(i) Personal details (e.g. name, date of birth, employer's information, business information)
(ii) Contact details (e.g. phone number, email address, postal address or mobile number)
(iii) Business information (e.g. employer name, job title, professional qualifications);
(iv) Transactional information (e.g. information about the Services you request or provide, information relating to any of your requests, queries or complaints);
(v) Your preferences for particular products or services when you tell us what they are; and
(vi) Your contact with us – such as a note or recording of a call you make to one of our staff members, an email or letter you send to us or other records of any contact you have with us.
1.2 Information Automatically Collected about You
(a) We automatically collect certain technical information from your computer or mobile device over time when you use these devices to access the Services, and will collect this technical information across different websites.
(b) The categories of personal information we collect about you automatically include:
(i) Browser details (e.g. Internet Protocol address, your browser type),
(ii) Device details (e.g. device model, MAC address, advertising identifier, operating system);
(iii) Precise real-time location information from your device's GPS. We will only collect this information with your consent. Once you have consented to this, you can adjust this consent by managing your location settings through your device or browser; and
(iv) Usage details (e.g. search requests and results, application usage data, and suggestions based on user actions).
(c) Some of this information may be collected through the use of "cookies" or similar technologies such as pixels, clear gifs or device fingerprints (together referred to as "cookies"). Cookies are small files that a site or its service provider may transfer to your computer's hard drive through your Web browser that enables the site's or service provider's systems to recognize your browser and capture and remember certain information.
1.3 Special categories of personal data
(a) We do not normally process any special categories of personal data (i.e. data concerning race, ethnic origin, politics, religion, trade union membership, genetics, biometrics (where used for ID purposes), health, sex life or sexual orientation) unless you voluntarily supply us with such data.
(b) If you supply us with any special category data, we will process such data in accordance with the law and only for the specific purpose for which you have supplied it (for example, if you tell us that you have a disability which means we need to make adjustments to the way in which we communicate with you).
2. Cookies And Similar Technologies
2.1 A cookie may be a 'session' cookie, that is, a cookie that remains on your device or browser while you are logged on to a particular web site and then disappears when you close your browser, or it may be a 'persistent' cookie, a cookie that remains on your browser over a period of time. Information from a cookie may be collected and used in aggregate form. Some cookies are placed directly by us, and others are placed by third party companies. Where they are placed by third party companies, they will be subject to the privacy policies of those third parties.
2.2 Some cookies are served directly by us, and others are served by third parties, such as by advertising and data analytics providers. We may use the following types of cookies:
(a) Essential cookies: these are operationally necessary for the functionality of the Services.
(b) Analytics cookies: we may use cookie analytic tools to collect information on how our Services are used and to report on our Services' usage statistics.
(c) Advertising cookies: we may work with third party advertising networks that collect information using cookies to help make the advertising you see on our Services and elsewhere on the internet more relevant to you, and to measure the effectiveness of the advertising on the Services.
2.3 You can make choices in relation to whether you accept cookies as described in the 'Your Rights Over Your Personal Information' section below.
3. How Do We Use Your Information?
3.1 We use your personal information to:
(a) provide you with products, services, or information you request, in order to meet our contractual obligations to you pursuant to any agreement between us;
(b) deal with your enquiries and requests;
(c) respond to your customer service requests and to communicate with you regarding your orders, or use of the Services, including by email or phone;
(d) comply with legal obligations to which we are subject and cooperate with regulators and law enforcement bodies;
(e) where we are permitted by law to do so (which in some circumstances may require that we obtain your consent in advance), deliver marketing communications, promotional materials, event invitations, or advertisements that may be of interest to you;
(f) allow us to improve the Services and the services we provide, such as by better tailoring our content to our users’ needs and preferences;
(g) generate and analyze statistics about your use of the Services;
(h) protect our rights, the integrity of the Services, or your safety or the safety of others;
(i) detect, prevent, or respond to fraud, intellectual property infringement, violations of our company policies, violations of law, or other misuse of the Services; and
(j) prevent and detect fraud or recover debts.
3.2 Unless otherwise described above, we will use the information in this way to meet our legitimate business interests. We have an interest in improving the functionality of the Services (through tailoring content, and analyzing statistics) to make sure you have the best experience using the Services, and an interest in communicating with you (through marketing, responses to customer service requests and content delivery) in a way that is most useful to you. We also have an interest in protecting our rights and upholding the law.
3.3 You can contact us using the details set out below for more information about our legitimate interests and the measures we have taken to ensure your rights are not infringed. Subject to local law, you can also object to any processing which we carry out on the basis of our legitimate interests.
3.4 We may also combine or aggregate any of the information we collect through the Services for any of these purposes.
3.5 We may obtain your consent to collect and use certain types of personal information when we are required to do so by law. If we ask for your consent to process your personal information, you may withdraw your consent at any time by contacting us using the details at the end of this privacy notice.
4. The Basis On Which We Use Your Personal Information
4.1 We must have a legal basis to process your personal information. In most cases the legal basis will be one of the following:
(a) To fulfil our contractual obligations to you, for example to provide the Services, to ensure that invoices are paid correctly, and to ensure you are able to access our Services when required. Failure to provide this information may prevent or delay the fulfilment of these contractual obligations.
(b) To comply with our legal obligations and enable our affiliates to comply with their legal obligations (which may apply under the laws of other countries around the world), for example, obligations relating to financial reporting and court orders.
(c) To meet our legitimate interests, for example to understand how you use our services, to enable us to recover debt, and to enable us to derive knowledge from that to enable us to develop new products and services. When we process personal information to meet our legitimate interests, we put in place robust safeguards to ensure that your privacy is protected and to ensure that our legitimate interests are not overridden by your interests or fundamental rights and freedoms. For more information about the balancing test that we carry out to process your information to meet our legitimate interests, please contact us at the details below.
5. How Do We Disclose Your Information?
(a) Service providers and business partners. We may share your personal information with our service providers and business partners that perform data management, network and marketing services and other business operations for us. For example, we may partner with other companies to process secure payments, fulfil orders, optimize our services, send newsletters and marketing emails, support email and messaging services and analyse information.
(b) PORTS group companies. We work closely with other businesses and companies that fall under PORTS worldwide. We may share certain information about the services you use, your location, and your contact information for marketing, administrative and internal reporting purposes. A list of PORTS' major group companies can be found in the annual report of Portico International Holdings Limited.
(c) Law enforcement agency, court, regulator, government authority or other third party. We may share your personal information with these parties where we believe this is necessary to comply with a legal or regulatory obligation, or otherwise to protect our rights or the rights of any third party.
(d) Asset purchasers. We may share your personal information with any third party that purchases, or to which we transfer, all or substantially all of our assets and business. Should such a sale or transfer occur, we will use reasonable efforts to try to ensure that the entity to which we transfer your personal information uses it in a manner that is consistent with this privacy notice.
5.2 We may also provide information we collect through the Services which has been anonymized to the extent that you are no longer identifiable to third parties for marketing, advertising, or other uses.
5.3 Because we operate as part of a global business, the recipients referred to above may be located outside the jurisdiction in which you are located (or in which we provide the services). See the section on "International Data Transfer" below for more information.
6. Your Rights Over Your Personal Information
6.1 You have certain rights regarding the personal information we hold about you, subject to local law. These include, to:
(a) access your personal information;
(b) rectify the information we hold about you;
(c) erase your personal information;
(d) restrict our use of your personal information ;
(e) object to our use of your personal information;
(f) receive your personal information in a usable electronic format and transmit it to a third party (right to data portability); and
(g) lodge a complaint with your local data protection authority.
6.2 If you would like to discuss or exercise such rights, please contact us at the details below. You also may also object to our uses of your personal information as described above.
6.3 Where you have provided your consent to any use of your personal information, you can withdraw this consent at any time.
6.4 If at any time you would like to unsubscribe from receiving future marketing emails, you can email us at firstname.lastname@example.org. Alternatively, you may follow the instructions at the bottom of each email and we will promptly remove you from all marketing correspondence.
6.5 We encourage you to contact us to update or correct your information if it changes or if the personal information we hold about you is inaccurate.
7. How Do We Protect Your Information?
7.1 We maintain administrative, technical, and physical security measures designed to safeguard the information collected by the Services. These measures are aimed at ensuring the on-going integrity and confidentiality of personal information. We evaluate these measures on a regular basis to ensure the security of the processing. However, no information system can be 100% secure, so we cannot guarantee the absolute security of your information. Moreover, we are not responsible for the security of information you transmit to the Services over networks that we do not control, including the Internet and wireless networks.
7.2 We will keep your personal information for as long as we have a relationship with you, and generally for a period of 3 years thereafter. We will only retain your personal information after this time if we are required to do so to comply with the law or the authorities, or if there are outstanding claims or complaints that will reasonably require your personal information to be retained.If there is any information that we are unable, for technical reasons, to delete entirely from our systems, we will put in place appropriate measures to prevent any further processing or use of the data.
7.3 If there is any information that we are unable, for technical reasons, to delete entirely from our systems, we will put in place appropriate measures to prevent any further processing or use of the data.
8. International Data Transfer
8.1 Your personal information may be transferred to, stored, and processed in Hong Kong, the United States and other countries.
8.2 Some of these countries may not be regarded as providing the same level of protection for personal information as the laws of your country. In such cases, we have put in place appropriate safeguards (such as contractual commitments) in accordance with applicable legal requirements to provide adequate protections for your personal information.
8.3 For more information on the above data transfer and the appropriate safeguards in place, please contact us at the contact information set forth below.
9.1 We may modify or update this privacy notice from time to time.
9.2 If we change this privacy notice, we will post a notice on our website or otherwise notify you of the changes. Where changes to this privacy notice will have a fundamental impact on the nature of the processing or otherwise have a substantial impact on you, we will give you sufficient advance notice so that you have the opportunity to exercise your rights (e.g. to object to the processing).
10. CONTACT US
10.1 You may request a copy of this privacy notice from us using the contact details set out above.
10.2 If you have questions or concerns regarding the way in which your personal information has been used, please contact us at email@example.com.
10.4 We are committed to working with you to obtain a fair resolution of any complaint or concern about privacy. If, however, you believe that we have not been able to assist with your complaint or concern, you have the right to make a complaint to the data protection authority of the country in which you live using their website.
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