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Privacy Policy

Effective Date: 12th March, 2019

 

  1. Introduction

EMQ Limited, together with its subsidiaries (“EMQ”, “we” or “us”), developed this privacy policy (“Privacy Policy”) to explain how we may collect, use, store, access, and disclose your Personal Information (as defined below) when you use EMQ’s websites, software programs and applications, including any components and updates thereto (collectively, the “Services”). We treat your information privacy very seriously and are committed to protecting the Personal Information you provide to us in accordance with this Privacy Policy.

The term “Personal Information” in this Privacy Policy refers to personal data as defined under the Personal Data (Privacy) Ordinance (Cap. 486) of the Hong Kong Special Administrative Region, which means any data relating directly or indirectly to a living individual from which it is practicable for the identity of the individual to be ascertained, in a format that makes access to or processing of that data practicable. For purposes of the Services, Personal Information may include, but is not limited to, your personal details, job particulars, and if applicable, financial information.

  1. Purpose

EMQ will collect your Personal Information only for the purpose of, and in connection with, providing the Services to you, responding to your inquiries, and, if necessary, authenticating your identity. EMQ may also use your Personal Information in compiling aggregate statistics and data on users of our Services as a whole, for the purpose of managing and improving our Services to you as well as our Services generally. In the event that EMQ wishes to use your Personal Information for any other purpose, EMQ will notify you of such intent and obtain your consent before doing so, unless such new purpose is required by applicable laws.

  1. Collection of Personal Information
    1. In order for us to provide the Services to you or to respond to your inquiries, EMQ may collect from you and hold some or all of the following information about you and, if applicable, your beneficiaries: (i) name; (ii) gender; (iii) photograph; (iv) address; (v) telephone number; (vi) mobile number; (vii) email address; (viii) date of birth; (ix) identification document type and number; (x) bank account information; and (xi) additional information that may be required for identity/account authentication.
    2. You acknowledge and agree that, where Personal Information relating to other individuals is disclosed to EMQ by you, you have provided a copy of this Privacy Policy to such individuals prior to your disclosure of their Personal Information to EMQ, and you have obtained all relevant consents from such individuals for the use of their Personal Information in the manner as described in this Privacy Policy.
    3. EMQ may gather and store in log files other automatically tracked information through technology, which information may reveal your activities but does not specifically identify you.For example, EMQ and our third-party marketing partners or analytics service providers may use technologies such as cookies, beacons, tags, and locally stored objects to gather information regarding the type of device, type of browser, operating system, Internet protocol (IP) addresses, internet service provider (ISP), geolocation, referring/exiting pages, and date/time stamps relevant to your usage of the Services.
    4. These technologies and data, both individually and in the aggregate, allow us to store your preferences and analyse trends so that we can improve or customize the Services provided to you, offer information more specific to your interests, and/or better understand the effectiveness of our promotional campaigns.Cookies and web beacons can usually be disabled by changing your browser preferences. Your browser usually has documentation on how to disable cookies and web beacons. Note that disabling cookies and web beacons may limit the performance and functionality of EMQ’s Services. Also note that because there is no generally accepted standard on how to respond to “do not track” browser-based signals, we do not respond to such signals.
    5. When you engage with our Services through social media or other third party platforms, plug-ins, or applications, you may allow us to have access to certain information in your profile, such as your name, email address, photo, gender, location, posts, and/or user ID associated with such services. For a description on how these social media or other third party platforms, plug-ins, or applications handle your information, please refer to their respective privacy policies, which may permit you to modify your privacy settings.
    6. By using our Services, you consent to the collection and use of your information as described in this Clause 3. If you do not wish to have your information collected and used in this manner, you must not use the EMQ Services.
  2. Use of Personal Information
    1. EMQ may from time to time, use your Personal Information to send you information that is relevant to our Services. If, at any time, you do not wish to receive that information, you may opt-out by notifying us at support-team@emq.com that you do not wish to be included in any future mail-outs.
    2. Your Personal Information held by us may be used for the following purposes:
      1. processing your request for Services and communicating with you;
      2. management, operation, audit, and maintenance of the Services;
      3. collecting money due from you (if any);
      4. designing new, or improving existing, Services provided by us;
      5. investigation of complaints, and prevention or detection of crimes;
      6. disclosure as required by applicable laws.
    3. Please note that the Services covered by this Privacy Policy may offer content or weblinks that are sponsored by third parties. We do not have control over these third party sponsors’ usage of any information you provide to them, which is subject to their own privacy policies. In addition, if you provide information to us in a manner that may be publicly viewable (such as through social media without limiting the audience), we cannot prevent further usage of such information by other parties.
  3. Disclosure of Personal Information
    1. We will safeguard your Personal Information collected by us in accordance with Clause 9 below. Subject to our obligations therein, we may, for the purpose(s) set out in Clauses 2 and 3 above, transfer or disclose such Personal Information to the following parties:
      1. Our partner banks and financial services companies;
      2. Our agents or contractors under a duty of confidentiality to us who provide administrative, telecommunications, data processing, payment, professional advisory, or other services to us;
      3. Our affiliates which owe a duty of confidentiality to us;
      4. Law enforcement agencies, judicial authorities, regulatory bodies and/or any person or entity to whom we have an obligation to disclose under applicable laws.
    2. In addition, EMQ may disclose your Personal Information to third parties for the following purposes:
      1. to protect our property, Services, and legal rights (including but not limited to debt collection);
      2. to support our audit, compliance, and corporate governance functions;
      3. to detect risks, prevent fraud, or assess suspicious activities;
      4. to manage credit reporting (if applicable);
      5. to facilitate a purchase or sale of all or part our business or assets; and
      6. in accordance with obligations imposed on EMQ by our third party service providers with respect to the provision of Services.
    3. Our network infrastructure involves computers, cloud-based servers, and third party service providers in multiple jurisdictions. The Personal Information that EMQ collects from you may be transferred to, and stored in, Hong Kong and/or a destination outside of Hong Kong. It may also be processed by persons operating within as well as outside of Hong Kong on behalf of EMQ. EMQ will take commercially reasonable steps to ensure that such Personal Information is treated securely and in accordance with this Privacy Policy within and outside of Hong Kong. However, we do not represent that our Services are appropriate or available in any particular jurisdiction. By using the Services or submitting your Personal Information, you consent to your Personal Information being transferred to, stored in, and processed in, Hong Kong as well as jurisdictions outside of Hong Kong, including jurisdictions that have different data protection rules than your home country.
  4. Limiting Collection and Retention of Information
    1. EMQ will limit the amount and type of information collected to that which is necessary to facilitate the Services and the information shall be retained only for as long as necessary for the fulfilment of the purpose for which it is collected.
    2. You acknowledge that EMQ is obliged under the relevant Hong Kong legislation to retain Personal Information for at least 7 years.
    3. Subject to any legislative requirements, EMQ will permanently destroy, erase, or make anonymous your Personal Information when it is no longer required to fulfil the purpose for which it has been collected.
  5. Accuracy

EMQ will make reasonable efforts to ensure that your Personal Information is sufficiently accurate. However, EMQ will not routinely update your Personal Information unless such process is necessary to fulfil the purposes for which the information was collected. Therefore, you must notify EMQ as soon as possible if any of the information you have provided to us has changed.

  1. Children’s Privacy

The EMQ Services are not directed at or intended for use by children under the age of 18 (“Minors”). EMQ will not knowingly collect or maintain Personal Information from Minors. If we obtain actual knowledge that we have collected Personal Information from a Minor, we will promptly delete it, unless we are legally required to retain such information.

  1. Safeguards
    1. EMQ has in place a range of security safeguards to protect your Personal Information held by us against unauthorized access, disclosure, processing, copying, use, erasure, or modification, regardless of the format in which it is held.
    2. The methods of protection EMQ employs may depend on the sensitivity of the information and the format in which it is contained. Security measures may include all or a combination of: technological measures including SSL encryption for all data transfers over the internet, physical measures such as locked filing cabinets and restricted access to offices, and strategic measures such as security clearances and limiting access on a “need-to-know” basis.
    3. You acknowledge that authorized employees, agents, representatives and third parties may require access to your Personal Information in order to enable EMQ to provide the Services to you. EMQ uses commercially reasonable efforts to ensure that our staff and third party service providers are aware of the importance of maintaining the confidentiality of Personal Information, will not keep any Personal Information for longer than is necessary, and will observe the requirements of this Privacy Policy. However, you acknowledge and agree that we cannot accept responsibility for any unauthorized activities on their part.
    4. You acknowledge that no data transmission over the internet or the telephone can be completely secure. Any Personal Information you submit to EMQ either electronically or over the telephone is done at your own risk. EMQ does not guarantee or warrant the security of information during such transmission. You acknowledge that third parties could unlawfully intercept your transmissions or may fraudulently instruct you to disclose Personal Information while posing as EMQ representatives.
    5. You further acknowledge and agree that you are solely responsible for securing and maintaining the privacy of your password(s) and account registration information, if applicable. You are also responsible for ensuring that your Personal Information held by us is accurate and current.
  2. Access
    1. You have the right to request a copy of some or all of your Personal Information retained by us, if any. We may charge you a fee as permitted by law for handling this query.
    2. If you notice any inaccurate or incomplete information held by us, you have the right to ask us to correct your Personal Information. We will respond to your request within a reasonable timeframe, take appropriate action to amend the information if warranted, and/or notify any third party of the correction as necessary.
    3. If you would like to make any request in accordance with this Clause 10, please email our Customer Support team at support-team@emq.com and provide us with appropriate supporting documentation. You acknowledge that there may be circumstances under which EMQ may refuse your data access request or correction request, including where the provision of access would involve unreasonable time and cost, where the information may contain references to other individuals, where EMQ deems, in our sole judgment, that such request was made in bad faith or for illegal purposes, or where EMQ determines, in our sole discretion, that provision of access would negatively affect our legal, investigative, security or proprietary processes or practices.
  3. Complaints; Changes
    1. EMQ has procedures in place to receive and respond to complaints or inquiries about our policies and practices relating to the handling of Personal Information.
    2. We take all complaints seriously and will investigate each of them.
    3. We may update this Privacy Policy from time to time to reflect changes to the Services, our privacy practices, or applicable laws. The revised Privacy Policy will be effective as of the published effective date. If we make any material changes, we will publish a notice of change through the applicable Service interface prior to the change becoming effective. EMQ encourages you to periodically review this Privacy Policy for the latest information on our privacy practices.
  4. Contact

If you have any queries about this Privacy Policy or our privacy practices, please contact our Data Protection Officer by email at privacy@emq.com or by writing to us at 2nd Floor, Talon Tower, 38 Connaught Road West, Sheung Wan, Hong Kong.