NOTICE TO CLIENTS RELATING TO PERSONAL DATA (PRIVACY) ORDINANCE (THE “ORDINANCE”)
This notice sets out the data policies of Emperio Gold and Silver Coins (Hong Kong) Limited (EMPERIO). The provisions of this Notice form part of the Account Terms and Conditions and/or the Agreement and/or arrangements that a Client enters into with EMPERIO. If any inconsistency is found, the provisions of this Notice shall prevail.
From time to time, it is necessary for clients to supply Emperio Gold and Silver Coins (Hong Kong) Limited (“EMPERIO”) with data in connection with the opening or continuation of accounts and the establishment or continuation of online shopping service. At the same time, some of the data are collected pursuant to laws, regulations, rules or codes binding on EMPERIO or any of EMPERIO’s Associated Companies.
Failure to supply such data may result in EMPERIO being unable to open or continue accounts or establish or continue providing online shopping services.
It is also the case that the data are collected from clients in the ordinary course of the continuation of the business relationship.
The purpose for which data relating to a client may be used are as follow:
- the daily operation of the services;
- ensuring ongoing credit worthiness of customers;
- designing marketing activities or related products for clients’ use;
- determining the amount of indebtedness owed to or by clients;
- collection of amount outstanding from clients;
- meeting the requirements to make disclosure under the requirements of any laws, regulations, rules, codes binding on EMPERIO or any EMPERIO’s Associated Companies; and
- purposes ancillary or relating thereto.
Use of data in direct Marketing
EMPERIO intends to use the client’s data in direct marketing and EMPERIO requires client’s consent (which includes an indication of no objection) for that purpose. If client does not wish EMPERIO to use his/her data for use in direct marketing client may exercise his/her opt-out right by notifying EMPERIO at any time and without charge. (To opt-out, please send your request to our customer services with your account number, phone number or other contact information by email firstname.lastname@example.org or post to 22/F., Everbright Centre, 108 Gloucester Road, Wanchai, H.K.)
Data held by EMPERIO relating to a client will be kept confidential but EMPERIO may provide such information to the following parties within or outside Hong Kong to the extent permitted by law:
- any agent, contractor or third party service provider who provides administrative, telecommunications, computer, payment or financial products clearing, printing or other services to GSPIYL in connection with the operation business;
- any other companies within EMPERIO’s Associated Companies, including the parent company;
- any other person under a duty of confidentiality to EMPERIO including a company of EMPERIO’s Associated Companies which has undertaken to keep such information confidential;
- any financial institution with which the client has or proposes to have dealings;
- any actual or proposed assignee of EMPERIO or participant or sub-participant or transferee of GSPI4L’s right in respect of the client;
- any other person when we are compelled to make disclosure under the requirements of any laws binding on EMPERIO or any of EMPERIO’s Associated Companies;
- any person with the Client’s express or implied consent;
- any person in the event that EMPERIO’s interests require disclosure;
In the course of performing our duties, EMPERIO may, as permitted by law, match, compare, transfer or exchange any persona data provided by the Client, or hereafter obtained, for these or any other purposes by EMPERIO, with data held by government bodies, other regulatory authorities, corporations, organizations or individuals in Hong Kong or overseas for the purpose of verifying those data.
Under and in accordance with the terms of the Ordinance, any individual:
- Has the right to check whether EMPERIO holds data about him/her and the right of access to such data;
- Has the right to require EMPERIO to correct any data relating to him/her which is inaccurate; and
- Has the right to ascertain EMPERIO’s policies and practices in relation to data and to be informed of the kind of personal data held by EMPERIO.
In accordance with the terms of the Ordinance, EMPERIO has the right to charge a reasonable fee for the processing of any data access request,
The person to whom requests for access to data or correction of data or for information regarding policies and practices and kinds of data held are to be addressed is as follows:
The Data Protection Officer
Emperio Gold and Silver Coins (Hong Kong) Limited
21/F, AT Tower, 180 Electric Road, North Point, Hong Kong