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This policy statement provides information on the obligations and policies of PCPD, its subsidiaries, affiliates, and associated companies (the "Company") under the Hong Kong SAR Personal Data (Privacy) Ordinance 1995 - Cap.486 (the "Ordinance").

Although this policy specifically addresses the Company's obligations in respect of the laws of the Hong Kong SAR, the Company believes the principles embedded in the Ordinance are equal to any in the world in respect of the protections they provide to an individual. As such, the Company undertakes to apply, where practicable, those principles and the processes set out herein to its operations globally.

Where the Company's operations are subject to privacy legislation other than that of Hong Kong SAR, then this policy shall be applied so far as practicable and consistent with such local legislation.

Throughout this policy, our use of the term "personal data" has the meaning ascribed to it by the Ordinance.


The Company shall fully comply with the obligations and requirements of the Ordinance. The Company's officers, management, and members of staff shall, at all times, respect the confidentiality of and endeavor to keep safe any and all personal data collected and/or stored and/or transmitted and/or used for, or on behalf of, the Company.

The Company shall endeavor to ensure all collection and/or storage and/or transmission and/or usage of personal data by the Company shall be done in accordance with the obligations and requirements of the Ordinance.

Where an individual legitimately requests access to and/or correction of personal data relating to the individual, held by the Company, then the Company shall provide and/or correct that data in accordance with the times and manner stipulated within the Ordinance.



For the purpose of carrying on the Company's business, you may be requested to provide personal data such as, but not limited to, the following, without which it may not be possible to satisfy your request:

(a) Your name;
(b) Contact details, including contact name and telephone number or email address; or

Information for the verification of identity, including identification type and identification number.

In some instances, you may also be requested to provide certain data that may be used to further improve our products and services and/or better tailor the type of information presented to you. In most cases, this type of data is optional although, where the requested service is a personalised service, or provision of a product is dependant on your providing all requested data, failure to provide the requested data may prevent us from providing the service to you. This type of data includes, but is not limited to:

(a) Your age;
(b) Gender;

Salary range and employment details;

(d) Education and Profession;
(e) Hobbies and leisure activities;
(f) Other related products and services subscribed to; and
(g) Family and household demographics.

The Company's web servers may also collect data relating to your online session, the use of which is to provide aggregated, anonymous, statistical information on the server's usage so that we may better meet the demands and expectations of visitors to our sites. This type of data may include, but is not limited to:

(a) The browser type and version;
(b) Operating system; and

The IP address and/or domain name.

Some of the Company's web sites may place a "cookie" on your machine; for example to provide personalised services and/or maintain your identity across multiple pages within or across one or more sessions. This information may include, but is not limited to, relevant login and authentication details as well as information relating to your activities and preferences across our web sites.


Where possible, we will validate data provided using generally accepted practices and guidelines. In some instances, we are able to validate the data provided against pre-existing data held by the Company. In some cases, as per the requirements of the Ordinance, the Company is required to see original documentation before we may use the personal data such as with Personal Identifiers and/or proof of address.

Although we do not currently provide online access to and correction of personal data held by the Company, we fully comply with the "Rights of Access and Correction" obligations of the Ordinance. Please refer to the section titled "Access and Correction of Personal Data " below for details on how you can obtain and correct any personal data relating to you that we may hold.


The Company will destroy any personal data it may hold in accordance with our internal retention policy. The policy states that:

(a) Personal data will only be retained for as long as is necessary to fulfil the original or directly related purpose for which it was collected, unless the personal data is also retained to satisfy any applicable statutory or contractual obligations; and
(b) Personal data are purged from the Company's electronic, manual, and other filing systems in accordance with specific schedules based on the above criteria and the Company's internal procedures.

All personal data held by the Company will be kept confidential but the Company may, where such disclosure is necessary to satisfy the purpose, or a directly related purpose, for which the data was collected provide such information to the following parties:

(a) Any subsidiaries, holding companies, associated companies, or affiliates of, or companies controlled by, or under common control with the Company;
(b) Any person or company who is acting for or on behalf of the Company, or jointly with the Company, in respect of the purpose or a directly related purpose for which the data was provided; and
(c) Any other person or company who is under a duty of confidentiality to the Company and has undertaken to keep such information confidential, provided such person or company has a legitimate right to such information.

Personal data may also be disclosed to any person or persons that have a right under the Ordinance to gain access to such information provided they are able to prove their authority to access such information. For example, if the Company were served with a court order demanding certain customer information then the Company would disclose the information to the duly appointed officer of the court or such other persons as the court orders.

At times it may be necessary and/or prudent for the Company to transfer certain personal data to places outside of the Hong Kong SAR in order to carry out the purposes, or directly related purposes, for which the personal data were collected. Where such a transfer is performed, it will be done in compliance with the requirements of the Ordinance.

Physical records containing personal data are securely stored in locked areas and/or containers when not in use.

Computer data are stored on computer systems and storage media to which access is strictly controlled and/or are located within restricted areas.

Access to records and data without appropriate management authorization are strictly prohibited. Authorizations are granted only on a "need to know" basis that is commensurate with an individual's Company responsibilities and their training.

Records of the Company are under the control of assigned information officers who are responsible to ensure the transfer of or access to information is legitimate and complies with the Ordinance.

Audit records may be produced to validate data modifications in order to verify the data's integrity.

There may be violations logging processes for investigation of any unauthorized attempt to access information.

Encryption technology, such as SSL, may be employed for the transmission of data collected online.


Under the terms of the Ordinance, individuals have the right to:

(a) Check whether the Company holds any personal data relating to them and, if so, obtain copies of such data;
(b) Require the Company to correct any personal data relating to them which is inaccurate for the purpose for which it is being used; and
(c) Ascertain the Company's policies and practices in relation to personal data, which are those policies and practices set out in their entirety herein.

During the recruitment process, job applicants may be required to provide sufficient personal data so that the Company may, as appropriate and/or applicable:

(a) Assess the applicant's suitability for the position being applied for;
(b) Assess the applicant's suitability for other positions the Company may have available;
(c) Determine preliminary remuneration and benefit packages;
(d) Verification of credentials and/or experience; and
(e) Perform security vetting and/or integrity checking

At a minimum, such personal data will include:

(a) The applicant's name and contact details, including address and telephone number(s);
(b) Previous employment and relevant experience; and
(c) Education and relevant training.

Additional information may also be required dependant on the nature of the position being applied for.

Additional information may also be required dependant on the nature of the position being applied for. The applicant is responsible for ensuring all personal data they provide is accurate and complete. The provision of inaccurate information or the withholding of requested information may prevent the Company from making an offer of employment, invalidate such offer if the inaccuracy or omission is discovered after an offer has been made, or lead to termination of employment if the inaccuracy or omission is discovered after employment has commenced.

The personal data so provided may be transferred to persons within the Company who are involved in the assessment of the applicant's suitability for the position applied for and/or other positions, which may be, or may become, available within the Company. The data may also be transferred to other third parties, such as investigation agencies, as are necessary to satisfy the purposes set out above.

The Company shall retain the personal data of unsuccessful applicants for future recruitment purposes for a period of two years from the date of application. The personal data of successful applicants shall be retained for the duration of their employment by the Company and as described below under the heading of "Employment, Including Post Employment".

In respect of the Company's practices regarding matters not directly addressed in this section "Recruitment", the practices, and procedures set out in the preceding sections of this Privacy Policy Statement shall apply.


In the course of employment by the Company, personal data of employees and their families, as appropriate, will be collected and used on an ongoing basis for various Human Resource purposes including but not limited to; administering staffing, performance management, training, career development, salary and benefits administration, communication, medical benefits, provident fund administration, insurance, taxation, welfare and providing information in compliance with legal requirements. It will be transferred to those internal departments, intra-company, and/or to other third parties as is necessary for the purposes.

The Company retains certain personal data of employees when they cease to be employed by the Company. Such data are required for any residual employment-related activities of the former employee including, but not limited to:

(a) The provision of job references;
(b) Processing applications for re-employment;
(c) Matters relating to retirement benefits; and
(d) Allowing the Company to fulfil contractual or statutory obligations.

Further details regarding the Company's polices and practices in respect of its handling of personal data relating to its employees, including post employment, are included in the Company's Human Resources Policies and Staff Handbooks. They are also available to the Company's employees from either the Company's Privacy Compliance Officer or directly from their respective Human Resources representative.


All enquiries regarding the Company's compliance with its obligations under the Ordinance should be in writing to:

PCPD Privacy Compliance Officer
8th Floor
Cyberport 2
100 Cyberport Road
Hong Kong
Or via email to:pcpd.privacy@pcpd.com