1. Introduction
ACCLOU (website url address: https://acclou.com) (“the Website”) is owned and operated by [ACCLOU] Limited (“the Company”, “we” or “us”), [a Hong Kong, China based company creating products to enhance business efficiency]. We respect personal data and are committed to full implementation and compliance with the data protection principles and all relevant provisions of Cap. 486 Personal Data (Privacy) Ordinance (“the Ordinance”) [of the HKSAR]. This Policy is applicable to the users of the Website as well as any other persons that their personal data is collected, by whatever means, used and held by us.
This Privacy Policy is applicable to all users of this Website, including but not limited to users of the Services as well as any other persons such that their personal data is collected, by whatever means, used and held by us.
2. Purposes of the Personal Data are Held
All personal data will be collected, used and held only by the Company.
You may provide us with your personal data at your own will. For using the services under this Website, all personal data, i.e. name, email address and contact number, physical address and/or district are regarded as mandatory. Your service request will not be considered if you fail to provide the said mandatory data.
The personal data collected from you will be used by the Company for the following purposes:
- Identification: verification of identity for handling requests of access, correction and erasure of personal data;
- Member Account and Class Handling: Registration for membership; identity verification; activity contact; class handling etc;
- Providing Services: To provide services to you through this Website, and to permit you to participate in other activities through this Website;
- Handling of Personal Data Requests: Verification of identity for handling requests of access, correction and erasure of personal data;
- Statistics: Carry out statistics and data analysis, such reports will contain only anonymous data for the Company’s reference as well as improving our service and product quality;
- Administration and Management: our internal administration and management, including auditing and internal analysis;
- Direct Promotions and Marketing: Only after obtaining your consent, the Company may send or contact you from time to time to share promotional or marketing information. Promotional and marketing subjects shall include promotion with our main business and other related business; and
- Transfer to Marketers/Talents: transfer your personal data to Talent (if you are Marketer) or Marketer (if you are Talent) for the purchase of products or provision of service , or enabling communication between the Marketer and the Talent for the provision or acceptance of any services or products.
3. Retention of Personal Data
The Company will retain all your personal data and the transaction records so long as is necessary for the fulfilment of (i) the purpose(s) for which they were collected and (ii) of the legal requirements. All your personal data and the transaction records will be destroyed thereafter.
Our information and data are stored and maintained in our electronic database, facilities, servers and back-up servers which may be located outside your country, where the legal protection and standard of security requirements may not be equivalent to the same provided by and legally required by the applicable laws and regulations of your country. You hereby expressly consent on our transferring, storing, maintain and retaining all your information and data in our electronic databases, facilitates, servers and back-up servers located outside your country for the purposes referred to in [Clause 3 > this Policy].
4. Accuracy and Change of Personal Data
In order to ensure the correctness of the members’ personal data, particularly contact details, retained by the Company, you may receive our request of confirmation or verification. Please feel free to contact us for correction or change of personal data or opt-out from receiving future direct promotional and marketing information.
5. Personal Data Handling and Security Measures
The personal data we collect about you will not be disclosed to any other party without your prior approval.
We have established in place security measures and monitoring procedures to prevent unauthorized or accidental access, processing, erasure, loss or use of the data. All personnel that may access to the data will be ensured complying with the requirements of data protection.
Our security measures are listed below:
- Controls on password complexity, re-tries or resets are implemented to prevent passwords from being compromised.
- Advanced encryption technology is used to protect the safety of personal data (including names, email addresses, physical addresses, telephone numbers, bank account information) during transmission. Our SecureSocketLayer (SSL) system will prevent your data being transmitted from unauthorized interception or access by third parties.
- Only the personnel that have been trained with the strict privacy guidelines and procedures are authorized to access or handle your personal data. Such personnel are accountable for non- compliance with the related obligations.
- The security system will be reviewed regularly.
Apart from statutory requirements, the Company will not transfer or disclose any of your personal data to any other parties.
6. Limitation of Liability
The Company has implemented all reasonably practicable procedures, measures and steps to safeguard the security of your personal data. However, no method of transmission over the Internet, or method of electronic storage, is totally secure. We cannot guarantee its absolute security. Unless there is proved negligence, we shall not accept any liabilities therefore.
7. Third Party Websites
After clicking on an advertisement or a hyperlink button on our website, you may have left our website and entered the website of a Company’s advertising client, content provider, supplier, associated company or business partner. Your visit to these third parties’ websites is not protected by this Policy.
These third parties’ websites are not owned or controlled by the Company. We have not authorized them to collect any personal data from you. Therefore, we are not responsible for any exposure of your data at these websites or losses arising from a third party website’s practice or policy. Please contact the manager or owner of such websites directly for any enquiries or questions about their own privacy practices or policies.
8. Cookies
We may use “Cookies” to improve our internet service and enhance your online experience. Cookies are small file that are automatically stored on your web browser in your computer that can be retrieved by the App/Website. Cookies may be used to remember you and your preferences when you visit the Website and enable us to tailor the App/Website to your needs. The information collected by Cookies is anonymous visitor’s personalized settings information and contains no name or address information or any information that will enable anyone to contact you via telephone, email or any other means. We will not collect any personal data from you when the cookies are being used. You can disable cookies by changing the settings of your web browser. Cookies cannot be used to run programs or deliver viruses to your computer.
9. Changes in this Privacy Policy
The Company may update or amend this Privacy Policy in the future, if necessary. The revised Policy will be posted on our website with an effective date. Please visit our website from time to time for the latest information.
10. Languages
Should there be any differences or inconsistencies between the Chinese version and English version of this Policy, the English version shall prevail.
11. Access to Personal Data
Under the Ordinance, you have a right to request access to, and to request correction of, your personal data in relation to your application. If you wish to exercise these rights, please contact us.
12. Contact Us
Should you have any requests (including Opt-out), enquiries or comments to our Privacy Policy or Practice, please leave us a message through the website. In general circumstances, your requests or enquiries will be handled within 14 working days after receipt of the same and verification of your identity.
13. Effective Date
This Privacy Policy becomes effective from 31 May 2018.
