PRIVACY POLICY
1. GENERAL
Admin Amigo (“we”, “us”, “our”) is committed to protecting the privacy and security of personal information provided to us in accordance with the Personal Data (Privacy) Ordinance Cap. 486 (“PDPO”). This includes personal information provided to us by customers and potential customers in the course of providing our services and products as well as by people visiting our website at www.amigo.hk (“Website”). Our Website is under the direct control of Shepherd Asia Limited. For more information about Shepherd Asia Limited and its services and products please visit www.shepherd-asia.com.
Information that you provide to us constitutes personal data if it relates directly or indirectly to you and either identifies you or can be used to do so.
The purpose of this Privacy Policy is to inform you as to how we collect, use and store personal data as well as your rights in relation to the data that you provide to us.
2. PERSONAL DATA COLLECTION
Your personal data shall be reasonably collected for lawful purposes only. Your personal data will be used for specific purposes stipulated in our Personal Information Collection Statement (see below). You are entitled to withdraw your consent to this use, at any time, by giving us prior written notice.
3. DIRECT MARKETING
Our use of your personal data for direct marketing (which includes business promotion) is subject to your consent. We will not sell or rent your personal data to any third party. If you wish to unsubscribe from our mailing list, please send an email to this effect to hi@amigo.hk.
4. PERSONAL DATA RETENTION
We will take reasonable steps to ensure that your personal data is retained only for as long as is reasonably necessary for the specific purpose(s) for which it was obtained and in accordance with the law. After that time, unless prohibited by law or some other limitation in the public interest, your data will be deleted.
5. DISCLOSURE, SECURITY & TRANSFER
We will undertake practicable measures, both technical and organisational, to hold your personal data and to prevent unauthorised use or access, processing, loss, and/or disclosure. Your personal data shall be used and disclosed only in accordance with our Personal Information Collection Statement.
For storage purposes, the data that you provide to us may be transferred, by our cloud service providers, to other jurisdictions outside of Hong Kong. In this instance, we will only use reputable providers to ensure the security of your data.
6. ACCESS & CORRECTION
You are entitled, in accordance with the PDPO, to have access to and to correct your personal data. Requests for access and/or correction should be addressed to Berrin Oenguen at: hi@amigo.hk. The PDPO, entitles us to charge a reasonable fee for processing any data access or correction requests, and in appropriate cases refuse such requests stipulating the reason for such refusal.
7. PERSONAL DATA (PRIVACY) ORDINANCE
You may wish to visit the official website of the Office of the Privacy Commission (https://www.pcpd.org.hk/) and Hong Kong e-Legislation (https://www.elegislation.gov.hk/) for more information about the PDPO.
8. Cookies
Our Website uses cookies which are small text files which provide information about you and your preferences. We use them to help improve your experience when visiting our Website but you can disable these cookies by editing your browser options.
We may also collect information regarding your IP address, browser type, domain name and access time. This information is used for our research purposes and as it is not linked to any personal information. In rare instances, IP addresses may be used to assist in deterring or preventing abusive or criminal activity on the Website.
PERSONAL INFORMATION COLLECTION STATEMENT
This Personal Information Collection Statement (“PICS”) sets out the purposes for which your personal data will be used after collection. You may be required to provide personal information to us when you use our services and/or purchase our products in the capacity of a client (or potential client), a user of our Website and other online services. We use cookies on our Website.
HOW WE COLLECT PERSONAL INFORMATION
The PICS applies to information we collect about you directly or indirectly whether through you or third parties. This may include the following situations:-
When you visit our Website (this includes information obtained through third parties, onboarded to build and/or host our Website);
When you subscribe to our mailing list, use our online services, purchase our online products and/or attend our events;
When you make enquires about our services, products, events and/or people;
When you are a potential client, a client or associated with our client(s) in the capacity of director, other officer, employee, staff member, authorised representative or other agents;
In the course of providing support and/or products to you which includes when you make payments, to us, using our third-party payment service providers;
In the course of managing our business activities; and/or
As and when required by law.
WHAT WE COLLECT AND WHY
We may collect personal information about you directly from you and/or from other sources including our clients (and their authorised representatives) and/or their counterparties. Information that we collect may include the following:
Identity:
We may collect information regarding your name, date of birth, former names, contact details such as email address, contact number(s), postal and residential address, occupation, nationality, gender, special information such as marital status, race, ethnicity, health related information, and documents in order to ascertain such information.Business information:
We may collect information regarding your business type and interests, purpose of your business transactions, work permits, information regarding your business associates (such as affiliated companies, partnerships, directors, shareholders, authorised representatives), business and billing addresses and website details.Accounts:
We may collect information such as bank account details, billing address, information required for processing payments, source of funds etc.Compliance:
We may collect all such information as required by law from time to time to fulfil any of our relevant legal/statutory obligations.Information in the public domain
We may collect information about you that is publicly available including but not limited to information from third parties such as government agencies, regulatory bodies, information service providers, credit reporting agencies, payment services providers and social media platforms.
SCOPE OF USE
We may use your personal information for the following purposes:
to fulfil our legal, regulatory and risk management obligations, including establishing, exercising, or defending legal rights;
when it is necessary for our legitimate interests or a third party’s legitimate interests subject to your fundamental rights. Legitimate interests include using your information for:
providing products and services to you;
promoting our business;
the functioning of our business and its operations (including the Website);
reasons required by applicable law; and
the development and improvement of our products and services.
to manage and administer our relationship with you and/or your representatives; and
We may also use your personal information:
where you have consented to the use in question; and/or
if you have already made said personal information public.
Your name, contact details and business name/logo may be used for promoting our business. You have the right to ask us, at any time, not to use your personal data for marketing purposes. You can exercise such right by sending an email stating this to hi@amigo.hk.
OPERATION
We hold your personal information for as long as necessary and in accordance with law.
We take appropriate technical and organisational measures to hold your personal data and to prevent unauthorised access, modification or disclosure. However, your data may be disclosed to and used by the following third parties:-
government agencies, courts, tribunals, regulatory authorities and law enforcement agencies, as required and permitted by the applicable law and regulations;
our professional advisors, auditors, insurers, banks, and information technology service providers;
third parties to whom we outsource certain services, including, but not limited to, translation, printing, transcription, document review, parties involved in hosting or organising events and debt collection agencies;
any third parties who are engaged in connection to the services/products we provide to you; and
our business partners.
In accordance with the terms of the Personal Data (Privacy) Ordinance (“PDPO”) and guidelines issued pursuant thereto, either you or any relevant person on your behalf may:
make a request to ascertain whether we hold personal data about you and may request access to such data;
request us to correct any data relating to you which is inaccurate;
request us to cease using the relevant personal data for its marketing purposes.
In accordance with the terms of the PDPO, we have the right to charge a reasonable fee for the processing of any data access request.
We reserve the right to reasonably refuse to comply with data access request where permitted or required by law.
If you need further information or have any questions or requests regarding our Privacy Policy or PICS, please write to:
Berrin Oenguen
Shepherd Asia Limited
9/F, BoC Group Life Assurance Tower
136 Des Voeux Rd Central,
Central
Hong Kong