Personal Data Privacy Policy and Personal Data Collection Statement

Overview

This policy statement provides information on Net Go Engineering Co., Ltd. (hereinafter referred to as the “Company”)’s obligations and policies in accordance with the Personal Data (Privacy) Ordinance (Chapter 486) of the Hong Kong Special Administrative Region (the “Ordinance”). Although this policy specifically sets out the Company’s responsibilities under the laws of the Hong Kong Special Administrative Region, the Company believes that the principles of personal data protection in the Ordinance are the same as those in relevant laws around the world. Accordingly, the Company implements these Principles and the procedures set forth herein wherever practicable throughout the world. Where the Company’s operations are subject to privacy legislation outside the Hong Kong Special Administrative Region, this Policy will be implemented to the extent practicable and consistent with such legislation. In this policy, the term “personal data” shall have the meaning given in the Ordinance.

Company Policy

The Company complies with the responsibilities and requirements of the Ordinance. Its subordinates, management and employees must always keep confidential and properly preserve all personal data collected and/or stored and/or transmitted and/or used by the Company (or on behalf of the Company). The Company ensures that all personal data collected and/or stored and/or transmitted and/or used must be handled in accordance with the obligations and requirements stipulated in the Ordinance. If an individual requests to obtain and/or correct his/her personal data held by the Company in a legal manner, the Company will provide and/or correct the above information in the time limit and manner prescribed by the Ordinance.

Personal Information Collection Statement

Categories of Personal Data Collected

The Company may require you to provide the following personal information in order to register and manage your services (including related online services). Without this information, it will not be possible to meet your service requests. Such information includes (but is not limited to):

  1. Name;
  2. Contact details, including name and phone number, or email address.

In some cases, you may be asked to provide certain information so that we can improve our products and services and provide you with information that suits your needs. In most cases, you can choose not to provide this information. However, if the relevant service is tailored to individual needs, or the supply of products requires you to provide all the required information, failure to provide such information may make it impossible for the Company to provide the required service. Such information includes (but is not limited to):

  1. Age;
  2. Gender;
  3. Salary level;
  4. Education level and occupation;
  5. Hobbies and extracurricular activities;
  6. Other related products and services used; and
  7. Family and household statistics.

Our web server will also collect information about your Internet connection in an anonymous form for the purpose of compiling aggregate statistics on server usage in order to enhance services and better meet the needs and expectations of visitors to our website. Such information includes (but is not limited to):

  1. Browser type and version;
  2. operating system; and
  3. Internet Protocol (IP) address and/or domain name.

Use of “Cookies”

When you browse our website, unless otherwise stated, we will only record your visit and will not collect any information that can identify you personally. Cookies used in any part of this website (if any) are not used to collect personally identifiable information. Cookies are computer files stored in Internet users’ computers and are used to obtain configuration information and analyze Internet users’ browsing habits. Cookies save you the trouble of having to re-register each time you visit a website and are commonly used to keep track of your favorite web page topics. You have the right to choose not to accept Cookies, but this may prevent you from using or activating certain features of our website.

Use of Personal Data

The personal data you provide to the Company will be used for the following purposes (“Specified Purposes”):

  1. Register on our website to use and/or activate certain features of our website;
  2. Provide and deliver to you the products/services you have ordered, reserved or requested and contact you regarding such products/services;
  3. To operate our business, including registering and managing our website;
  4. Sorting and analyzing data so that the Company can better understand your characteristics and purchasing behavior, provide you with other services that better meet your needs, and assist the Company in selecting products/services that may be of interest to you;
  5. Comprehensive customer behavior analysis, and any other analysis, survey or research on any of the Company’s products/services;
  6. Direct marketing of lifestyle products to you and sending you Net Go Engineering Co., Ltd. newsletters (if any);
  7. Any other management, operation and maintenance of our products/services/websites; and
  8. Used in accordance with legal requirements.

Retention of Personal Data

The Company will destroy the personal data it holds in accordance with its internal retention policy. This policy states:

  1. Personal data will be retained for as long as necessary to achieve the specified purpose; unless such personal data is required to be retained under any applicable laws or contracts; and
  2. In accordance with the above criteria and the Company’s internal procedures, personal data will be cleansed from the Company’s electronic, manual and other storage systems after a specific storage period.

Disclosure of Personal Data

All personal data held by the Company will be kept confidential, however, the Company may disclose such data to the following persons when it is necessary to disclose such data to achieve the specified purpose:

  1. Any subsidiary, holding company, associated company, or company or associated company held by the Company or under the same control as the Company;
  2. Any individual or company acting on behalf of the Company or in association with the Company for the purpose of achieving a designated purpose;
  3. Any other person or company who is obliged to keep the above information confidential for the Company and who has a legal right to access the information;
  4. any person who is entitled to access the data under the Ordinance, provided that he or she proves his or her right to access the data; and
  5. Disclosure to any entity upon order of a court or government agency. For example, if a court issues an order requiring the Company to provide certain client information, the Company will disclose such information to a person duly appointed by the court.

Security of Personal Data

Physical records containing personal data are kept in secure, locked storage when not in use. Computer data is stored in computer systems and storage media with restricted access, and access to data is strictly controlled. No one who is not officially authorized by management shall have access to records and data. Such rights are only granted on a “need to know” basis and are based on the individual’s responsibilities and training within the Company. The Company’s records are controlled by designated data specialists who are responsible for ensuring that the transfer or access of data is legal and in compliance with regulations. The Company may raise audit records to verify changed data and determine the integrity of the data. The Company may have procedures in place to record breaches in order to investigate unauthorized attempts to access information. When transmitting sensitive information collected online, the Company may use encryption technology such as SSL.

Query and correct personal data

Under the Ordinance, individuals may have the right to:

  1. to ascertain whether the Company holds personal data about him/her and, if so, to obtain a copy of such data;
  2. Request the Company to correct any inaccurate personal data concerning him/her in order to achieve the purpose of using the data; and
  3. Confirm that the Company’s policies and practices regarding his/her personal data are generally consistent with the provisions of this Policy and Practices.

Individuals can log in with a preset user name and personal password to exercise their rights. Once the Company is satisfied with the authenticity and validity of the access request, it will endeavor to comply with the request and respond within the time limit prescribed by the Ordinance. Individuals can exercise their right to make corrections by logging in with their preset username and password. Once the Company is satisfied with the authenticity and validity of the request for correction, it will endeavor to comply with the request and respond within the time limit prescribed by the Ordinance.

Direct Mail

According to the regulations, the Company will comply with the individual’s request and will not use their personal data for direct marketing purposes. Without your consent or indication of no objection, the Company will not use your personal data for direct marketing or provide it to others for direct marketing. Even if you have provided your consent, you still have the right to opt out of receiving direct marketing materials at any time. If you wish to switch to or not receive direct marketing materials from the Company, please email us at [email protected] or unsubscribe from receiving direct marketing materials through the unsubscribe link in our newsletter. You may also change your email address to receive direct marketing materials. (If there is any discrepancy between the Chinese and English versions, the English version shall prevail.)