Privacy Policy

This Privacy Policy ( "Policy ")explains what you can expect from us and what we need from you in relation to your personal data. Please read this carefully as this Policy is legally binding when you use our services.

We want you to understand why and how HKB Corporate Services Limited ( "HKB") collects, uses, discloses and or/processes your Personal Data (as defined below) under Hong Kong's Personal Data Privacy Ordinance (Cap. 486) (the "PDPO ")and the European General Data Protection Regulation (the "GDPR ").

This Policy applies to you and all Individuals (as defined below) who provide HKB with Personal Data or whose Personal Data is otherwise collected, used, processed, stored and/or disclosed by HKB in connection with and/or for the purposes of its operations.

This Policy supplements but does not supersede or replace any previous consent which you may have provided to HKB, nor does it affect any legal rights that HKB may have regarding the collection, use, processing and/or disclosure of any Individual's Personal Data.

HKB may from time to time update this Policy to ensure that it is consistent with our business needs or to accommodate amendments to applicable legal or regulatory requirements. All updates to this Policy will be published online on the Website. Notification of any material revisions will also be published on the Website. You shall be deemed to have accepted the Policy as amended by continuing your relationship with HKB after any amendments have been published on the Website.

This Policy forms part of the terms and conditions, if any, governing your specific relationship with HKB ("Terms and Conditions")and it should be read in conjunction with the Terms and Conditions. In the event of any conflict or inconsistency between the provisions of this Policy and the Terms and Conditions, the provisions of the Terms and Conditions shall prevail to the fullest extent permissible by law.

For the purpose of this Policy:

"HKB DPO" shall mean the Data Protection Officer based in Hong Kong. He/She can be reached at the following address:

1103, 11/F, 88 Gloucester Road, Wan Chai, Hong Kong

Our principles of data protection

Our approach to data protection is based on the following principles:

You have full control over your data and you have the ability to make changes as required.
Open, honest and transparent.
We secure Personal Data entrusted to us.

1. Definitions: For the purposes of this Policy:

"Individual" (or "you")means a natural person, whether living or deceased and "Individuals" (and "your") shall be construed accordingly;

"Personal Data" means data that is capable of identifying an Individual, whether on its own or in conjunction with other data accessible to HKB;

"Personnel" means any Individual engaged under a contract of service with HKB and its affiliates including permanent or temporary employees as well as trainees and interns engaged by HKB from time to time; and "Potential Personnel" means any Individual who has submitted an application to be engaged by HKB as Personnel.

"Website" means collectively this website and any of its pages including the APP and the use of any of our services

2. Purposes for collection, use and disclosure of Personal Data

HKB will only collect, use and disclose Personal Data from/or related to an Individual that is reasonably considered necessary for the relevant purposes underlying such collection, use or disclosure, which may include but is not limited to the following:

a) Facilitating the provision of products and services which are used by you whether in Hong Kong or elsewhere by HKB, its partners and affiliates;
b) To provide from time to time with newsletters, marketing or promotional materials and any other information that may be relevant to you from HKB or its partners and affiliates in Hong Kong or elsewhere where the information may be shared or transferred;
c) Communicating with you about our services including management and billing or to assist you with your enquiries;
d) Dealing with administrative matters relating to the product and/or services purchased and/or subscribed to by you;
e) Conducting market research and customer satisfaction surveys;
f) To satisfy HKB's contractual, legal and regulatory requirements;
g) To improve our services and to develop new services and products;
h) To perform statistical analysis of behaviour and characteristics to measure interest and use and to inform advertisers of such information. HKB may provide individual or aggregated data to third parties, partners and affiliates, whether in Hong Kong or elsewhere;
i) To prevent, detect and fight fraud or other illegal or unauthorised activities k) Any other purposes that we notify you of at the time of obtaining consent (collectively known as the "Purposes").

3. Collection of Personal Data

Generally, HKB may collect Personal Data from you in one or more of the following ways or circumstances:

a) Information provided directly: You may be asked to provide Personal Data when you visit or use some parts of our Website and/or services. You do not have to provide us with your Personal Data; however, it could mean that you are not able to access some parts of our website or use our services.
b) Information collected automatically: Some information is collected automatically, such as an IP address and device type, when you visit our Website or use our services. This information is useful to us as it provides us with a better understanding of how you are interacting with our Website and services so that we can continue to provide you with the best experience possible.
c) Information from third parties: The majority of information that we collect is collected directly from you. Some data may be collected from other sources, such as information that is available in the public domain or trusted third parties in order to conduct background checks as part of your relationship with us. We use this information to supplement the Personal Data that we have collected from you.

Where your Personal Data is collected from third parties, we will only use such Personal Data where you have provided your consent to the third party which would also cover our processing of your Personal Data or where HKB has a legitimate interest to use the Personal Data in order to evaluate the suitability of your relationship with us.

Some of the information we collect may include your personal data, such as your full name, contact information, Copy of HKID, Copy of passport or other identification, telephone number(s), residential address, email address, biometric data and other personal information required by government agencies, product and service selections, and other data that may identify you. We collect personal data about you at several different points, including but not limited to the following:

when we correspond with you as a customer or prospective customer;
when you visit the Website or use the platform;
when you use our software or services;
when you register as an end-user of our services and an account is created for you;
when you opt-in our services;
when you voluntarily provide us with your information through our landing pages

As part of our on-boading process, there is some information which we have to collect from you as part of being licensed (License No. TC007626) as a Trust and Company Service Provider (TCSP) or for the provision of our services without which we would not be able to provide you our services. In order to do so, we may make use of independent providers to help us carry out identity checks on our behalf. When this happens, you will be redirected outside of HKB's platform. The information required might include an image, images of an identity document (e.g a passport or a driver's license) or a live video. The exact information needed depends on the check that's being carried out.

We seek to protect the information we share by imposing contractual privacy and security safeguards on the recipient of the information. Whenever redirected outside of HKB, we encourage you to read the provider's relevant privacy policy in order to have a better understanding on how your data is being processed.

4. Processing of Personal Data

Where we collect Personal data, we will only process it:

a) To perform a contract with you, or
b) Where we have a legitimate interest to protect the Personal Data which is not overridden by your rights, or
c) In accordance with a legal obligation, or
d) Where we have your consent.

Please note that if you choose not to provide us with your Personal Data or choose not to consent to our processing of your Personal Data, we may not be able to provide some or all of our services to you or respond to your other requests; for job applicants, we would not be able to evaluate your suitability against our employment opportunities.

5. Sharing Information Outside HKB

HKB may share information with partners, affiliates and external parties that are performing tasks on our behalf (including data processors and sub-contractors) and with other companies, affiliates, organisations, government bodies, and individuals outside HKB where we have a legitimate legal reason for doing so (for example in connection with any merger or acquisition or to comply with a court order, or for marketing and promotional purposes) or where you have consented to or where we have been instructed to share the information on behalf of our clients.

6. Consent

Unless otherwise authorised under the APP, PDPO, GDPR or any other applicable law, HKB will not collect, use or disclose your Personal Data without your knowledge and consent. HKB will highlight the Purposes relevant to you, by appropriate means, at the point or time of collection of your Personal Data.

HKB may obtain your consent by any of the following means:

a) via express provisions in a contract, application form and/or registration form to be signed with or submitted to HKB;
b) via notifications on HKB's websites;

In so far as any Purpose(s) are intrinsic to the relationship or provision of services, HKB reserves the right to decline to engage in the relevant relationship or to provide the relevant services to you if you do not consent to HKB's collection, use or disclosure of your Personal Data for such purposes.

If you:

voluntarily provide Personal Data to HKB for any specified purpose;
use or access HKB's website(s) or computer network;
enter HKB's premises or use any of the facilities thereon; and/or
attend or participate in events or programmes organised by HKB.

You will be deemed to have agreed and consented to HKB collecting, using and/or disclosing their Personal Data in the manner and for the purposes set forth in this Privacy Policy.

If you provide HKB with Personal Data relating to a third party (e.g. information of his or her spouse or children) for any particular purpose, you represent to HKB that you have obtained the consent of the relevant third party for HKB to collect, use or disclose such Personal Data for the relevant purpose.

7. Disclosure of Personal Data

There may be occasions where we may need to share your Personal Data with third parties. HKB will disclose your Personal Data only in the following circumstances:

c) to HKB's third party service providers, affiliates or agents;
d) to HKB's auditors and professional advisors;
e) to regulators, law enforcement bodies, government agencies, courts or any other third party to whom disclosure is permitted or required by any applicable law or regulation;
f) to other parties where we have your consent.

8. Request to Withdraw Consent

You have the right to withdraw your consent to the collection, use and/or disclosure of your Personal Data in the possession of HKB by contacting HKB's Data Protection Officer at (852) 3690 8231.

We will process your request for the withdrawal of consent within a reasonable period of time from such a request being made. After that time, we will not collect, use and/or disclose your Personal Data in the manner stated in your request.

Your withdrawal of consent could affect the services that we are able to provide to you. Depending on the extent of your withdrawal of consent for us to process your Personal Data, it may mean that we are not able to continue with our existing business relationship.

9. Cookies

We may place and access certain cookie on your computer and/or any electronic device used to access the Website. A cookie is a small piece of data that is stored on your computer and/or any electronic device. We use cookies to improve your experience using the Website and to improve our services. With regards to data that is collected by cookies, you may disable the use of cookies on your internet browser when accessing HKB's Website. However, disabling the use of cookies may result in the loss of functionality, restrict your use of the website and/or delay or affect the way in which HKB's website operates.

10. Security of Personal Data

HKB shall make reasonable security arrangements to prevent unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks to Personal Data in its possession.

If HKB transfers Personal Data outside of Hong Kong, HKB will take reasonable steps to ensure that such Personal Data transferred receives a standard of protection comparable to the protection received under the PDPO and such transfer shall be subject to this Policy.

HKB will ensure that third parties who receive Personal Data from HKB protect such Personal Data in a manner consistent with this Policy and not use such Personal Data for any purposes other than those specified by HKB, by incorporating appropriate contractual terms in its written agreements with third parties.

HKB is not responsible in any way for the security and/or management of Personal Data shared by you with third party websites accessible via links on HKB website.

In the event of a breach of security in respect of any Personal Data, HKB shall promptly (but as soon as practical from a security perspective) provide notice of such breach to the customer and any individuals acting on behalf of such customer, setting out the extent of the breach, the affected Personal Data and any steps taken by HKB to remedy and limit the consequences of the breach. Notwithstanding the foregoing, where HKB determines that the PDPO allows HKB not to provide notification in respect of a breach, HKB may choose not to inform the customer of such breach immediately or at all.

11. Third party websites

Our Website may, from time to time, contain links to and from the websites of our partner networks and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility for them. Please check these policies before you submit any Personal data to these websites.

12. Accuracy of Personal Data

Information voluntarily provided by you to HKB shall be deemed complete and accurate.

HKB will take reasonable steps to verify the accuracy of Personal Data received at the point of collection, but you will remain primarily responsible and liable to ensure that all Personal Data submitted by you to HKB is complete and accurate.

HKB will also take reasonable steps to periodically verify the Personal Data in its possession, taking into account the scope of its operations. However, you remain responsible for notifying HKB, from time to time, of any applicable changes to your Personal Data. You can notify the Personal Data Officer of any changes to your Personal Data by contacting (852) 3690 8231.

HKB shall not be held liable for any inability on its part to provide services to you if you fail to ensure that your Personal Data submitted to HKB is complete and accurate.

13. Access to and correction of Personal Data

In general, the rights afforded to individuals are:

a) Right to Access

The right to be informed of and request access to the Personal Data that we process about you. This will enable you to check what Personal Data we are processing and whether the processing is lawful.

We will respond to your access request as soon as reasonably possible. Should we not be able to respond to your access request within 30 days after receiving your access request, we will inform you in writing via email within 30 days of the time by which we will be able to respond to your request. If we are unable to provide you with any personal data requested by you, we shall generally inform you of the reasons why we are unable to do so (except where we are not required to do so under the PDPO or under any other applicable laws).
b) Right of Correction/Rectification

The right to request that we amend or update your Personal Data where it is inaccurate or incomplete. Kindly note that while we shall make a reasonable effort to ensure that the Personal Data we collect is accurate and complete, you are responsible for ensuring the accuracy of the Personal Data that you provide to us directly.

We will respond to your correction request as soon as reasonably possible. Should we not be able to perform the correction request within 30 days after receiving your request, we will inform you in writing via email on the time by which we will be able to perform your correction request. If we are unable to perform a correction requested by you, we shall generally inform you of the reasons why we are unable to do so (except where we are not required to do so under the PDPO or under any other applicable laws).
c) Right to Withdraw Consent

You have right to withdraw your consent at any time, where consent is the legal basis of the processing of your Personal Data. Kindly note that depending on the nature and scope of your request, we may not be in a position to continue performing our obligations in the course of or in connection with the Event to you.

For individuals covered by the GDPR, they also have the following rights (as available and subject to any applicable law):
d) Right to Erasure

The right to request that we temporarily or permanently stop processing all or some of your Personal Data.
e) Right to Object

The right to object to your Personal Data being processed by us for direct marketing purposes, or to, at any time, object to us processing your Personal Data on grounds relating to your particular situation.
f) Right to Data Portability

The right to request a copy of your Personal Data in electronic format and the right to transmit that Personal Data for use in another party's service.
g) Right not to be subject to Automated Decision-making

The right to not be subject to a decision based solely on automated decision-making where the decision would have a legal effect on you or produce a similarly significant effect.

If we send you marketing messages based on your consent or as otherwise permitted by applicable law, you may, at any time, respectively withdraw such consent or declare your objection at no cost. If you wish to "unsubscribe" from receiving our marketing messages you can contact: (852) 3690 8231. Please note that if you opt-out of receiving marketing materials, we may still send you non-promotional messages, such as receipts or information about the services we are providing to you.

Additionally, you have the right at any time to lodge a complaint with your local Data Protection Authority if you are unhappy with the way in which we are using your Personal Data.

In order to enable you to exercise these rights with ease and to record your preferences in relation to how HKB uses your Personal Data, you may contact us at (852) 3690 8231.

For more information on how we respond to your requests please contact (852) 3690 8231.

14. Retention of Data

The length of time that we keep your Personal Data depends on what it is and whether we have an ongoing business need to retain it.

We will only retain your data for as long as we have a business relationship with you and for a period of time afterwards where we have an ongoing business need to retain it, or where we are required by law to retain it.