This Statement is, except where separate and distinctive statements are provided, applicable to Acelegal including but not limited to its affiliates. Accordingly, references to “we”, “us”, or “our company” shall mean, as the case may be, the relevant companies within the Acelegal.

Please note that this Statement may be amended from time to time without prior notice. You are advised to check for the latest version on a regular basis.

1. Privacy Policy Statement

1.1 Our Pledge

We are committed to safeguard the privacy of individuals with respect to your personal data. We assure that our policies and practices, and those adopted by our affiliated companies and agents in relation to the collection, use, retention, disclosure, transfer, security and access of your personal data comply with the requirements under the Personal Data (Privacy) Ordinance (Chapter 486) (the “Ordinance”) under the laws of Hong Kong, as well as the relevant code of practice and guidance issued by the Office of the Privacy Commissioner for Personal Data, Hong Kong. The meaning of the term “personal data” adopted in this Statement is defined in the Ordinance.

Where our Services are subject to privacy legislation other than that of Hong Kong (such as due to our carrying out of operational functions outside of Hong Kong), this Statement shall apply so far as it is consistent with such local legislation.

1.2 Collection of personal data

During the scope of our Services, you may be required to provide your personal data including, but not limited to, your name, mobile number, email address, credit card information etc. Refusal to provide such information may render us unable to handle any application or request you are making, or may deny you access to certain parts of our websites, or may otherwise defeat the objectives of your visit.

1.3 Use of personal data collected

Specific purposes for which your personal data may be used are set out in our “Personal Information Collection Statement” set out in Part 2 below (particularly those contained in points (i) through to (viii) in the first paragraph of Part 2.1 below).

1.5 Data access and correction

Under the Ordinance, you have the right to:

1. Check whether we hold any of your personal data;
   ii. Access your personal data held by us;
   iii. Request us to correct any inaccurate personal data held by us; and
   iv. Ascertain our policies and practices established (from time to time) in relation to personal data and the types of personal data held by us.

If you want to access and/or correct your personal data which you have given us via application form, internet or other means, or if you want to ascertain our policies and practices in relation to personal data and the kind of your personal data held by us, please contact our Data Protection Officer in writing, we will respond within 40 days after receiving the request. We may charge you a reasonable fee for each personal data access. However, such fee will be waived if the data access is made for the purpose of correcting your personal data.

1.6 Security of personal data

We use various encryption techniques to transmit via the Internet your personal data, which can only be accessed by our authorized personnel. Given the operational nature of the Internet, we cannot guarantee that the transmission is fully secure.

1.7 Retention of personal data

Your personal data which you have given us during the service subscription period will be retained for a reasonable period after termination of your subscription. We will erase any unnecessary personal data from our system in accordance with our internal policy.

2. Personal Information Collection Statement

2.1 As a customer of our company, or a visitor or user of our website(s), it may be necessary for you to provide us with your personal data when you apply to us and/or continue to subscribe with us for any service and/or product. If your personal data is incomplete or incorrect, we may not be able to provide or continue to provide the services to you. We shall keep your personal data confidential at all times. Our policies and practices with respect to the collection, use, retention, disclosure, transfer, security and access of personal data will be in accordance with requirements under the Ordinance and this Statement. We may use and retain the personal data provided by you for the following purposes and for other purposes as shall be agreed between you and us or required by law from time to time:

1. Processing of your service application, and provisioning of the services;
   ii. Processing of any payment instructions;
   vi. Facilitating the daily operation of your account, provisioning of customer services and/or the collection of overdue amounts in your account in relation to the services;
   vii. Enabling us to perform any obligations on interconnection or conform with other industry practices, or to comply with any requests stipulated by governmental or regulatory authorities; and
   viii. Enabling us in prevention of crime.

2.2 We may disclose and transfer (whether in Hong Kong or overseas) your personal data to the following parties to use, disclose, process or retain your personal data for the purposes mentioned above:

1. Our agents and contractors;
   ii. Our affiliated companies and business partners;
   iii. Banks, financial institutions and credit providers;
   iv. Debt collection agencies, credit reference agencies and security agencies;
   v. Regulatory bodies, law enforcement agencies and courts; and
   vi. Our professional advisers.
2. Security Statement

While internet is not an inherently secure environment for communications, security of internet communications can be enhanced by the application of appropriate technology. However, internet security is not solely a technical issue, knowledge on security of personal and transaction data as well as general measure are equally important. “Hackers” could only attack a system through a “door”. However, in most cases imprudent transmission and handling of sensitive data such as confidential documents, password, personal identifiers etc. would facilitate unauthorized access to such a “door” by “hackers”. Hence, internet users should be cautious when handling such kind of sensitive documents and data.

In order to prudently preserve all personal data obtained from users of our websites, apart from firewalls and other sophisticated technical facilities, we also provide and maintain other stringent security measures so as to protect our system as well as the information and data retained therein from accidental or malicious destruction or damage.

4. Enquiries

Should you have any enquiries concerning this Statement, please feel free to contact our Data Protection Officer in writing by email at:

By E-mail: info@acelegalservices.com