8 September 2017
Topo Solutions Limited and/or its subsidiary(ies) and/or affiliates (hereinafter collectively referred to as the “Company”) pledges to meet fully with the requirements of Cap 486 of the Personal Data (Privacy) Ordinance of the Laws of the Hong Kong Special Administrative Region. In doing so, the Company will ensure compliance by its staff to the strictest standards of security and confidentiality in respect of all personal information and data submitted by users via topo.cc, its sub-domains, and any other websites, media platforms, or applications including the Mobile Application operated by the Company (hereinafter collectively referred to as the “Channels”) and the Company will not release such information to anyone without the prior consent of the relevant user(s) of the Channels (whether registered or not) (the “User” or the “Users”), except to the authorised persons listed in Paragraph 3 below.
1. Purpose of Collection of Personal Data
1.1 In the course of using the Channels, Users may disclose or be asked to provide personal information and/or data. In order to benefit from and enjoy the various services offered by the Channels, it may be necessary for Users to provide the Company with their personal information and/or data. Although Users are not obliged to provide the information and/or data as requested on the Channels, the Company will not be able to render certain services on the Channels in the event that Users fail to do so.
1.2 The Company’s purposes for collection of information and data on the Channels include but are not limited to the following:
(a) to perform the daily operation of the services provided to Users;
(b) to identify Users who have posted advertisements, materials, messages, photos, views, or comments or such other information (collectively “Information”) on the Channels;
(c) to identify Users who have viewed the Information posted on the Channels;
(d) to identify Users who have enjoyed their benefits as members of the Channels by receiving and using marketing and promotional materials;
(e) to provide Users with a platform and forum for posting photos and sharing and discussing their insights;
(f) to allow members of the Channels to enjoy their benefits as members by enrolling for special events hosted by the Company;
(g) to enable the Company to select and present information that matches the needs of Users or to create personalised contents;
(h) to design and provide products and services to Users in relation to the above purposes;
(i) to compile and analyse aggregate statistics about Users’ use of the Channels and service usage by Users for the Company’s internal use; and
(j) to facilitate the Company use of Users’ personal data for purposes relating to the provision of services offered by the Company and marketing services, special events, and/or promotions of the Company and/or its clients.
1.3 The Company strives to collect only personal data which is necessary and adequate but not excessive in relation to the purposes set out above.
1.4 If the User is under the age of 3, the Company strongly recommends that he or she seeks prior consent from a parent or guardian, who may contact the responsible personnel of the Company at email@example.com to register the User as member of the Channels.
1.5 If the Company requires the User’s personal data for a purpose other than those set out hereinabove, the Company may request the User’s prescribed consent to the same. If the User is a minor, the prescribed consent should be given by his or her parent or guardian.
2 Collection of Personal Data
2.1 The Company may collect personal information and/or data about the User, such as his or her name, login ID and password, address, email address, phone number, age, sex, date of birth, country of residence, nationality, education level, and work experience that is not otherwise publicly available. Occasionally, the Company may also collect additional personal information and/or data from the User in connection with contests, surveys, or special offers.
2.2 Only duly authorised staff of the Company will be permitted to access the User’s personal information and data, and the Company shall not release such personal information and data to any third parties save and except for the circumstances listed out under the Paragraph 3 entitled “Disclosure or Transfer of Data”.
3 Disclosure or Transfer of Data
3.1 The Company agrees to take all practicable steps to keep all personal information and data of Users confidential and/or undisclosed, subject to the following conditions.
Generally speaking, the Company will only disclose and/or transfer the User’s personal information and/or data to the Company’s personnel and staff for the purpose of providing services to the User. However, the Company may disclose and/or transfer such information and/or data to third parties under the following circumstances:
(a) where the information and/or data is disclosed and/or transferred to any third party suppliers or external service providers who have been duly authorised by the Company to use such information and/or data and who will facilitate the services on the Channels, under a duty of confidentiality;
(b) where the information and/or data is disclosed and/or transferred to any agents or associates of the Company who have been duly authorised by the Company to use such information and/or data;
(c) where the Company needs to protect and defend its rights and property;
(d) where the Company considers necessary to do so in order to comply with the applicable laws and regulations, including without limitation compliance with a judicial proceeding, court order, or legal process served on the Channels; and
(e) where the Company deems necessary in order to maintain and improve the services on the Channels.
3.2 Personal data collected via the Channels may be transferred, stored, and processed in any country in which the Company operates. By using the Channels, the User is deemed to have agreed to, consented to, and authorised the Company to disclose and/or transfer his or her personal information and data under the circumstances stated above, as well as to any transfer of information (including the Information) outside of the User’s country.
4.1 Any User is entitled to request access to or make amendments to his or her own personal information and data kept with the Company by contacting the Customer Service Representative of the Company at +852 3018 8089 or email to firstname.lastname@example.org.
4.2 In the event that a User wishes to access or amend his or her personal information and data, the Company may request him or her to provide personal details in order to verify and confirm his or her identity. A HKID card number or passport number or business registration certificate number cannot be amended unless such data is proved to be inaccurate. The Company is required to respond to a User’s request within 14 days of his or her request and will endeavor to do so wherever possible.
5 Cookies and Log Files
5.1 The Company does not collect any personally identifiable information from any User whilst they visit and browse the Channels, save and except where such information of the User is expressly requested. When Users access the Channels, the Company records their visits only and does not collect their personal information or data. The Channels’ server software will also record the domain name server address and track the pages the Users visit and store such information in cookies, and gather and store information like Internet protocol (IP) addresses, browser type, referring/exit pages, operating system, date/time stamp, and clickstream data in log files. All these are done without the Users being aware that they are occurring.
5.2 The Company and third-party vendors engaged by the Company use the Company’s cookies and third-party cookies to inform, optimise, and serve marketing materials based on the Users’ past visits to the Channels.
5.3 The Company does not link the information and data automatically collected in the above manner to any personally identifiable information. The Company generally uses such automatically collected information and data to estimate the audience size of the Channels, gauge the popularity of various parts of the Channels, track Users’ movements and number of entries in the Company’s promotional activities and special events, measure Users’ traffic patterns, and administer the Channels. Such automatically collected information and data will not be disclosed save and except in accordance with the Paragraph 3 entitled “Disclosure or Transfer of Data”
6.1 The security of Users’ personal information and data is important to the Company. The Company will always strive to ensure that Users’ personal information and data is protected against unauthorised access. The Company has implemented appropriate electronic and managerial measures in order to safeguard, protect, and secure Users’ personal information and data.
6.3 The Company follows generally accepted industry standards to protect the personal information and data submitted by Users to the Channels, both during transmission and once the Company receives it. However, no method of transmission over the Internet, or method of electronic storage, is completely secure. Therefore, while the Company strives to protect Users’ personal information and data against unauthorised access, the Company cannot guarantee its absolute security.
7 Retention of Personal Data
Once the Company has obtained a User’s personal information and/or data, it will be maintained securely in the Company’s system. Subject to legal requirements, the personal information and/or data of Users will be retained by the Company after deactivation of the relevant service until the User requests the Company in writing to erase his or her own personal information and/or data from the Company’s database or to terminate his or her membership of the Channels.
9 Governing Law and Jurisdiction
For any query, please contact our Customer Service Representative at +852 3018 8089 or email to email@example.com