1. The Stylus Limited (“The Stylus”) pledges to meet and comply with the requirements of the Personal Data (Privacy) Ordinance (Cap.486 of the Laws of Hong Kong) (“Ordinance”). In doing so, The Stylus has committed itself to protect and keep in strict confidence any personal data (as defined below) collected.
2. This Statement is important and should be read thoroughly in order to understand the privacy policies of The Stylus in respect of any personal data it collects from you, as a data subject (as defined below).
3. The Stylus may amend, update, vary or add to this Statement from time to time without any prior notice as necessary and any revised Statement will be published on The Stylus.
4. By accessing and using this website and any of its pages, you are agreeing to the terms and conditions set out herein.
5. If there is any inconsistency between the English version and the Chinese version of this Statement, the English version shall prevail.
Type of Personal Data
6. The term “personal data”, wherever mentioned in this Statement, includes the following kind of information:
a. All the data which may be collected or held by The Stylus from time to time in connection with the registration and establishment of user’s account or the use or continuation of provision of The Stylus services, products and facilities, the following data relating to a data subject (including any updated data of any of the following data):
2.date of birth;
3.correspondence address and/or residential address;
7. information as referred to in the paragraphs below under ‘Cookies, Domain Names and IP Addresses’;
8. The term “data subject(s)”, wherever mentioned in this Statement, includes the following categories of individuals:
a. The Stylus’s customers; and
b. users of this website;
8. For the avoidance of doubt, “data subjects” shall not include any incorporated bodies. The contents of this Statement shall apply to all data subjects and form part of any contracts for services that the data subjects have or may enter into with The Stylus from time to time. If there is any inconsistency or discrepancy between this Statement and the relevant contract, this Statement shall prevail insofar as it relates to the protection of the data subjects’ personal data. Nothing in this Statement shall limit the rights of the data subjects under the Ordinance.
Cookies, Domain Names and IP Addresses
10. “Cookies” are small bits of information that are automatically stored in your computer hard drive which can be retrieved by this website.
11. Cookies can make the site more useful by storing information about your preferences on particular websites and thus enabling The Stylus as website owners to provide more useful features for its users. The information collected by cookies is anonymous aggregated research data, and contain no name or address information or any information that will enable anyone to contact you through telephone, e-mail or any other means. Most web browsers are initially set to accept cookies and if you would prefer, you can disable the functionality of cookies. However, by disabling cookies, you may not be able to take full advantage of the website.
12. Every time you log on to this website, The Stylus will, through its network servers, automatically collect your domain name and IP address for the purpose of verification and The Stylus will use such data for visitor flow statistical and data analysis.
13. the website contains links to other sites that are operated by third party companies with different privacy practices. You should remain alert when you leave The Stylus’s website and read the privacy statements of other websites. The Stylus has no control over any personal that you submit to or receive from these third parties.
Collection of Personal Data
14. From time to time, it is necessary for the data subjects to supply The Stylus with personal data in connection with the registration and establishment of user’s account or the use or continuation of provision of The Stylus services, products and facilities.
15. The Stylus may work with third parties that use applications or computer technologies to find out more about users of the website.
16. Failure to supply such personal data may result in you being unable to register and establish a user account or use or continue the provision of The Stylus services and products and facilities.
Protection of Children under the age of 18
17. Data subjects who are under the age of 18 must obtain permission from their parents or legal guardians before providing any personal data to The Stylus. This website is not designed for persons aged below the age of 18 years and does not knowingly collect personal data about those persons aged below the age of 18 years. The Stylus will delete those personal data if The Stylus becomes aware that it has recklessly collected personal data about visitors aged below the age of 18 years.
Purposes of Use of Personal Data Collected
18. The purposes for which the personal data relating to the data subjects may be used will vary depending on the nature of the data subjects’ relationship with The Stylus, they may include the following :
a. assessing the merits and suitability of the data subjects as actual or potential applicants for The Stylus’s services, products and facilities;
b. conducting statistical and data analysis;
c. communicating with data subjects or its authorised;
d. enabling The Stylus to ensure smooth operation of the products, services and facilities provided to the data subjects, and to improve, optimize and configure the services for the data subjects;
e. researching and/or designing and/or implementing The Stylus’s related services, products and facilities;
f. marketing services, products and other subjects (please see further details related to ‘Direct Marketing’ below);
g. performing investigation or inquiry of any illegal conduct;
h. complying with obligations, requirements, arrangements or procedures that apply to The Stylus or that it is expected to comply according to:
1.any law binding or applying to it within the Hong Kong Special Administrative Region (“Hong Kong”) existing currently and in the future;
2.any guidelines or guidance given or issued by any legal, regulatory, governmental, tax, law enforcement or other authorities, or self-regulatory or industry bodies within Hong Kong existing currently and in the future; and
3.any contractual obligations or other commitment applying to it under any contractual arrangement The Stylus has with its agent, representative, contractor, business partner or other third party which The Stylus has entered into a contractual relationship with;
i. purposes incidental, associated or relating to any of the above items (a) to (i).
Transfer of Personal Data Collected
19. Personal data held by The Stylus relating to data subjects will be kept confidential but The Stylus may provide and disclose (as defined in the Ordinance) such personal data to the following parties for the purposes set out in the previous paragraph:
a. any agent, contractor, business partner or other third party which The Stylus works together with in its provision of such service, product or facility, wherever situated;
b. any party that a data subject has initiated a business transaction with or will make a payment to or through;
c. any party to whom The Stylus is under an obligation or otherwise required to make disclosure under the requirements of any law binding or applying to it within or outside Hong Kong, or any disclosure under and for the purposes of any guidelines or guidance given or issued by any legal, regulatory, governmental, tax, law enforcement or other authorities, or self-regulatory or industry bodies with which The Stylus is expected to comply, or any disclosure pursuant to any contractual or other commitment of The Stylus, all of which are within Hong Kong and may be existing currently and in the future.
Storage of Personal Data and Security
20. All personal data collected from data subjects will be stored in secure servers of The Stylus in order to prevent any unauthorized or accidental access, processing or erasure.
21. The Stylus maintains this commitment to data security by implementing appropriate physical, electronic and managerial measures to safeguard and secure personal data.
22. The Stylus will take all practical steps to ensure that personal data will not be kept longer than necessary and The Stylus will comply with all statutory and regulatory requirements of Hong Kong concerning the retention of personal data.
23. While The Stylus does everything it can to protect personal data from unauthorized use, processing and disclosure, data subjects should take precaution not to share, provide or facilitate unauthorized use of an unique username and/or password assigned by The Stylus or allow access or use of it by others. If, in the unlikely event, unauthorized transactions have been discovered through no fraud, fault or negligence on the part of data subjects, the data subjects should inform The Stylus immediately.
24. The Stylus intends to use the data subject’s data in direct marketing and The Stylus requires the data subject’s consent (which includes an indication of no objection) for that purpose.
25. The specific requirement regarding data subject’s consent (which includes an indication of no objection) under Part VIA of the Ordinance shall take effect on 1st April 2013. In this connection, please note that:
a. the name, correspondence address and/or residential address, telephone number; and/or email address of the data subject held by The Stylus from time to time may be used by The Stylus in direct marketing and the following classes of services, products and subjects may be marketed:
i. The Stylus’s services, products and facilities
b. other than marketing the above services, products and subjects itself, The Stylus does not intend to provide any personal data to any third party for use in direct marketing, and The Stylus requires the data subject’s written consent (which includes an indication of no objection) for that purpose.
26. A data subject may communicate its consent to The Stylus to so use of his/her personal data in direct marketing in accordance with the above through the means below:
By email: email@example.com
and The Stylus will then, at no cost to the data subject, act on the consent to direct marketing within 90 days.
27. After a data subject has consented to direct marketing, if a data subject does not wish to receive any marketing and other promotional materials from The Stylus, a data subject can always have an opportunity to opt-out by the means as set out in paragraph 26 above. The Stylus will then, at no cost to the data subject, act on the request to opt-out within 90 days and ensure that the data subject will not include in future direct marketing promotions.
Rights of Access or Correction of Personal Data
28. In accordance with the terms of the Ordinance, The Stylus has the right to charge a reasonable fee for the processing of any data access request. Any data access request must be made in writing and with completed form as prescribed under the Ordinance.
29. The persons to whom requests for access to data or correction of data or for information regarding policies and practices and kinds of personal data held are to be addressed is as follows:
By email: firstname.lastname@example.org
Last update: 1 Sep 2019