- What personal data about our visitors and users do we collect;
- With whom do we share personal data about our visitors and users;
- How long do we store personal data about our visitors and users;
- What requests can you do in order to manage the processing of your personal data;
- Contact details of Us.
Please note that this Policy shall not be applied to the processing of your personal data if this processing will be based on the contract with you.
The Information about Us.
The Data User in the meaning of the Personal Data (Privacy) Ordinance (Cap. 486), or, in the meaning of the European Regulation, data controller, is the following Company: WONDER UNION LIMITED, incorporated and registered under the laws Hong Kong Special Administrative Region of the People’s Republic of China, with its registered number 1744757, with its registered address at Hong Kong, San Po Kong KL New Tech Plaza 34 Tai Yau street 23 Floor, Room 2303 (“Company”, “We”, “Us”, “Our”). Our e-mail address for complaints, feedbacks and questions: email@example.com.
Definition of Personal data.
Personal Data (Privacy) Ordinance (Cap. 486) defines “personal data” as any data:
(a) relating directly or indirectly to a living individual;
(b) from which it is practicable for the identity of the individual to be directly or indirectly ascertained;
(c) in a form in which access to or processing of the data is practicable.
What personal data about our visitors and users we collect?
We do not track, monitor or otherwise process the personal data of our users and visitors by automatic means or when they use the Website. When you send Us a message to our e-mail address or contact us via the interface of the Website, you can, by your own initiative, provide us with the data, that fall within the definition of “personal data” in the meaning of the applicable legislation. These data may include, without limitation:
– Your name;
– Your e-mail;
– Additional contact details that you may specify;
– The subject of your request/message/feedback/proposal.
How collected personal data will be used?
The personal data, collected from you, shall be used for the following purposes:
– To respond to your request/message/feedback/proposal;
– To provide you with the Services, offered on the Website;
– To comply with the laws Hong Kong;
– To comply with the law of other jurisdiction(s) (if the legislation of Hong Kong provides this compliance);
– Additionally, we may anonymize collected personal data and perform analysis on how visitors and users of the Website use our Website. These data shall contain anything, from which it is practicable for the identity of the individual to be directly or indirectly ascertained.
To whom may we share collected personal data?
Personal data, collected from the users and visitor of our Website, may be shared with the following persons and entities:
– Employees, sub-contractors and affiliates of the Company;
– Service providers. Those include, but not limited to hosting providers, software providers;
Google LLC. We use Google Services, provided by Google LLC., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA, which includes Google Analytics, Google Tag Manager and Google reCAPTCHA (if applicable).
- Google Analytics. The Website uses Google Analytics, a web analytics service. The information generated to a Google server in the USA and stored there. Google Analytics Opt-out Browser Add-on provides visitors and users with the ability to prevent their data from being collected and used by Google Analytics. To install Google Analytics Opt-out Browser Add-on, follow this link: https://tools.google.com/dlpage/gaoptout?hl=en.
- Google Tag Manager. Google Tag Manager is a tool made by Google that allows Us to integrate and manage tags (snippets of code) into our Website.
- Google reCAPTCHA (if applicable). We use Google reCAPTCHA. reCAPTCHA protects the Website from spam and abuse. This tool is primarily used to distinguish whether an input is made by an individual or robot, algorithm, code, or by any other form of automated processing.
Cloudflare, Inc. We use the services, provided by Cloudflare, Inc. 101 Townsend St, San Francisco, CA 94107 USA. Сloudflare provides web optimization and security services that We use to improve and protect the Website, including a reverse proxy, pass-through security service. Cloudflare may collect the log data from the visitors of the Website. Additionally, We deployed a Cloudflare`s cookie file for security purposes. To find out more about processing of the data by Cloudflare, please follow https://www.cloudflare.com/privacypolicy/.
– Governmental authorities. We will share your personal data to them only if we will be obliged to perform this disclosure under the applicable legislation.
How long collected personal data be stored?
We shall process collected personal data as long as required for the purposes of the processing. For example, we shall store the personal data, provided in your request as long as may be required for the purpose(s) of the processing of your request. In some cases, the period of storage may be prolonged if required by the applicable legislation. When the purposes of the processing are reached, collected personal data shall be erased.
Notification for the Residents of the European Union.
Please note that our Company is established in the Hong Kong Special Administrative Region of the People’s Republic of China. Accordingly, your personal data will be processed in the country with the personal data protection legislation that differs from the legislation in force in the European Union. If you do not agree to the processing outside the European Union, please, do not provide us with any personal data about you.
Data Subject`s requests (data management).
Under the Cap. 486 Personal Data (Privacy) Ordinance of the Laws of Hong Kong, you are given with a right to control your data processing through the requests. If you or a person authorized by you in writing want to apply any, please, do not hesitate to contact us via email firstname.lastname@example.org. You can make the following requests:
Data access request. You have the right to be informed whether we hold your personal data and if we hold such data, to be supplied by us with the copy of such data.
Data correction request. You can always request us to make a correction to the data you have previously submitted to us.
Additional Rights for the residents of the European Union.
If you are the resident of the European Union, in addition to the rights, mentioned above, you have additional rights, which you may realize us via email email@example.com:
The right to withdraw your consent. You can withdraw previously given consent for the processing of your personal data. Please note that the withdrawal shall not affect the lawfulness of the processing that was carried out before the withdrawal.
Right to restriction of the processing. You can request us to restrict the processing of your personal data if one of the following conditions is met:
- the accuracy of the personal data is disputed by you. In this case, the restriction shall be made for a period enabling Us to verify the accuracy of the personal data;
- the processing is unlawful and you oppose the erasure of the personal data and requests the restriction of their use instead;
- we no longer need collected personal data for the purposes of the processing, but they are required by you for the establishment, exercise or defence of legal claims.
Please note that:
- We may ask additional proof(s) of your personality before the realization of any right or request specified herein.
- Realization of some rights and requests may be restricted or denied by the applicable legislation. In this case, you shall be provided with the ground of the restriction or denial.
The information for the complaints.
For any complaints and feedback(s) you can contact us via e-mail firstname.lastname@example.org. Additionally, you can follow the Website of the Privacy Commissioner for Personal Data of Hong Kong and direct the Commissioner your complaint (if any) – www.pcpd.org.hk.
Changes and Amendments to this Policy.
This Policy may be changed, modified or revised from time to time. Thus, you are required to check this Policy periodically for any changes. We will notify you of any changes by posting the new version of the Policy on this page or by sending an email notification (if applicable). Your continued use of the Website or continued communication with Us shall be considered as your consent with the new revision of the Policy.
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How can you control Cookies?
Most browsers allow to control and manage the cookies. The “Help” or “Setting” tab in your browser shall provide you with the proper functionality. Here you can find the guidelines for cookie management for the most widely spread types of browsers:
Cookies used by the Website.
|Name of the cookie||Source||Expiration time||Purpose of use|
|__cfduid||The Cloudlfare.||1 month.||This cookie is a security feature deployed by US in order to protect this Website. The _cfduid does not allow for cross-site tracking. It also does not allow for Cloudflare to follow visitors from site to site by merging various _cfduid identifiers into a profile. Rather, Cloudflare places the _cfduid cookie in a visitor’s web browser after the user has met certain security requirements. The _cfduid is a one-way hash of certain values and cannot be used to personally identify the individual.|
|_ga||Google Analytics.||2 years.||These cookies are used to collect information about how visitors use the Website. We use the information to help us improve and enhance our Website.|