PRIVACY POLICY
Last modified:
January 23, 2021
This Privacy Policy describes how https://www.oceanmaterial.com (collectively referred to as “OM, “us”, “we” or “our”) collects, uses, and process your personal data in accordance with the Personal Data (Privacy) Ordinance (Cap. 486 of the Laws of Hong Kong) (“ PDPO”), the associated regulations and guidelines as may from time to time be issued by the Privacy Commissioner for Personal Data, Hong Kong and (where applicable) the General Data Protection Regulation (EU) 2016/679 (“GDPR”) of the European Union.
This Privacy Policy is designed to assist you in understanding how we collect, use, disclose and/or process the personal data you have provided to us, as well as to help you to make an informed decision before providing us with your personal data.
1. INTRODUCTION
We intend to collect, use, process and disclose your personal data in the manner set forth in this Privacy Policy.
2. INFORMATION COLLECTION
There are two broad categories (A/B) of information that we collect from you:
A. Personal Data and Online Identifiers
“Personal data” means any information relating to an identified or identifiable natural person; an identifiable natural person is one who can be identified, directly or indirectly.
- We collect certain types of personal data, including your name, gender, date of birth, identification numbers, company (if applicable), contact information (e.g. address, phone number, email address), payment information (e.g. credit or debit card information), photographs and video footages taken at events organized by us and/or our business partners and any other information which you may provide in any forms submitted to us or via other forms of interaction with us.
- It is voluntary for you to supply your personal data to us, although you may not be able to use our services or acquire our goods if you do not supply your personal data. We may not process your order for goods and/or services, and no contract for provision of such goods and/or services will be formed, if you do not supply the personal data required on our relevant order/subscription forms.
- We may also obtain personal data about you from other sources and combine it with information you provide to us. If you provide us with any personal data relating to a third party (e.g. information of spouse, children, parents, employees and/or authorized representatives), by submitting such information to us, you represent to us that you have obtained the consent of the third party to you providing us with their personal data for the respective purposes.
- When you visit and use our websites, we may also collect information about you using online identifiers such as cookies.
B. Non-Personal Data
We also collect certain non-personal data when you visit and use our websites. Such data is entirely anonymous and is aggregated for statistical analysis (“Aggregate Information“).
Like many website operators, we may use an independent company (the ” Third Party Market Research Company“) to measure and analyse usage across our websites. We use the Third Party Market Research Company’s services to collect Aggregate Information on the usage of our websites, including the following:
The number of page views (or page impressions) that occur on our websites;
The number of visitors to our websites;
How long these visitors (on average) spend on our websites when they do visit; and
Common entry and exit points into our websites.
This Aggregate Information is collated by the Third Party Market Research Company and provided to us to assist in analysing the usage of our websites. This is so that we can improve the content and navigability of our websites as well as our services and facilities.
3. USE OF INFORMATION
The purposes for which information may be used by us in and outside Hong Kong include:
- products and services to you ordered or requested (e.g. shipping material samples) and to manage your membership subscriptions for additional content and services
- verification of your payments
- editorial purposes
- services to facilitate trade between Hong Kong and overseas (or otherwise), and providing enquirers with contact and business information
- our operations, e.g., incorporation into our database, analysis, research and auditing
- notification of OM initiatives, workshops, trade fairs and events in Hong Kong or around the world; organized by us or our business partners and counterparts
- distribution of OM publications and research materials (and those of our business partners and counterparts)
- marketing OM services or products (and those of our business partners and counterparts engaged in similar or peripheral activities, such as business matching services, sourcing and conferences)
- complying with laws, regulations or codes of practice in or outside Hong Kong
- legal proceedings, including collecting overdue amounts
- other purposes directly relating to the activities identified above
- prevention or detection of crime, and protection of the security and safety of our events and trade fairs
- verification of identity in events organised by us where it is necessary to verify your identity
Your personal identification data such as date of birth and nationality (if collected by us) will be used solely for the purpose in (k) above. Your photo, passport or identity card number & copy will be used solely for the purposes in (k) and (l) above.
We may conduct direct marketing via fax, email, direct mail, telephone and other means of communication whether now or hereafter known, or send e-newsletters to you. You may choose not to receive promotional materials, by simply telling us (see below for contact details), and we will cease to do so, without charge. If applicable law requires that we receive your explicit consent before we send you certain types of marketing communications, we will only send you those types of communications after receiving your explicit consent.
4. DISCLOSURE
In order to facilitate our business operations and provision of goods and services, your personal data may be disclosed, for one or more of the purposes listed in paragraph 3 above, to the following third parties (whether located in Hong Kong or abroad):
- personnel, agents, advisers, auditors, contractors, financial institutions, and service providers in connection with our operations or services
- our overseas offices, promotional event, affiliates, business partners and counterparts
- persons under a duty of confidentiality to us
- persons to whom we are required to make disclosure under applicable laws in or outside Hong Kong
- actual or proposed transferees or participants of our services
In situations in which the above third parties receive your personal data from us, we will require the third parties to exercise reasonable care in protecting your personal data so that it is in compliance with the PDPO and (where applicable) the GDPR.
5. COOKIES
Cookies are small data files sent to your browser or device to store information about you when you visit our websites. Cookies will do a lot of different jobs, such as letting you navigate between pages efficiently, identify your behaviour, remembering your preferences and generally improving your user experience. They can also help to ensure that the advertisements you see online are more relevant to you and your interests.
Most browsers automatically accept cookies. You can, however, modify your browser settings to disable cookies. If you choose to do so, some of the functionality of our websites may be impaired.
We may also use cookies from third parties to help us provide you and others with social plugins and other customized content and experiences.
Some cookies will not collect information that personally identifies you. They will collect more general information such as how users arrive at and use our websites, or a user’s general location. However, some other cookies can identify you and may contain or collect personal data. The type of information OM collects as a result of a cookie is specific to your computer and may include, without limitation, the Internet Protocol (IP) address and the date and time you accessed our websites. The data stored on a “cookie” can be retrieved by OM when you visit our websites.
When you visit our website(s), you will see a pop-up seeking your consent to the placing and use of cookies on your device. You may either give such consent or reject the placing and use of cookies. You can also remove existing cookies from your device using your browser options. If you want to block future cookies being placed on your device you can change your browser settings to do this. For more information on managing cookies see aboutcookies.org, which contains comprehensive information about how to restrict or block cookies on a wide variety of browsers.
6. SECURITY
We take the security and protection of your personal data very seriously. As such, we store your personal data on secure servers and have put in place appropriate security arrangements to prevent unauthorized access, collection, use, disclosure, copying, modification, disposal of your personal data.
However, we cannot assume responsibility for any unauthorized use of your personal data by third parties which are wholly attributable to factors beyond our
7. HYPERLINKS
OM may contain links to external sites operated by third parties for your convenience. We have no control of and are not responsible for these third party sites or the content thereof. Once you leave the Site, we cannot be responsible for the protection and privacy of any information which you provide to these third party sites. You should exercise caution and look at the privacy statement for the website you visit.
8. DATA TRANSFER
The personal data that we collect or obtain from you may be transferred to jurisdictions that offer lesser protection of personal data than that provided in your jurisdiction. In particular, we may transfer your personal data to Service Provider(s) in jurisdictions outside the EEA and Hong Kong. Such transfer, if subject to the GDPR, would be made with appropriate or suitable safeguards (the details of which can be obtained from our Data Protection Officer) or with your explicit consent. Such transfer may present possible risks for you due to the lack of an adequacy decision or appropriate safeguards.
9. THIRD-PARTY SITES
Our websites may contain links to other websites operated by third parties such as our business partners. We are not responsible for the privacy practices of websites operated by third parties that are linked to our websites. You are encouraged to learn about the privacy policies of such third party websites. Some of these third party websites may be co-branded with our logo or trademark, even though they are not operated or maintained by us. Once you have left our websites, you should check the applicable terms, conditions and policies of the third party website to determine how they will handle any information they collect from you.
10. CHANGES
We may update this Statement. When we do, the changes will be posted on https://www.oceanmaterial.com/privacy
11. YOUR DATA PRIVACY RIGHTS
You may request to access or correct your information in accordance with the PDPO. We may charge a reasonable fee for the processing of such data access request(s).
In addition, where you are a data subject in the EEA, in certain circumstances you have the right under the GDPR to:
- access and rectify your personal data;
- request us to erase your personal data without undue delay;
- restrict how we process your personal data;
- where our processing of your personal data is based on consent, withdraw your consent at any time;
- object to our processing of your personal data on the basis of legitimate interests, unless we demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms or for the establishment, exercise or defence of legal claims;
- object to direct marketing (including any profiling for such purposes) at any time;
- receive your personal data which you have provided to us, in a structured, commonly used and machine-readable format and to transmit such data to another data controller without hindrance from us; and
- lodge a complaint with a supervisory authority.
Where you are a data subject in the EEA, we will not charge a fee when we deal with your requests to exercise the rights above.
If you wish to exercise one of the above mentioned rights, cease marketing communications, and/or raise questions or complaints please contact us at:
Kennedy Town, Hong Kong
E-mail: [email protected]
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