Throughout this Privacy Policy, the term “personal data” means any data relating directly or indirectly to you, from which it is practicable for your identity to be directly or indirectly ascertained, and in a form in which access to or processing of the data is practicable.
Corporate and Security Solution Limited and CASSolution Macao Limited (collectively referred to as “CASSolution”, “us”, “we” or “our” in the following) take your privacy very seriously. This Privacy Policy is intended to state your rights, and to govern its collection and processing activities on your personal data. If you need more information, please contact: info@cassolution.com.
If you have entered a contract with CASSolution, the controller of your data will be Corporate and Security Solution Limited and CASSolution Macao Limited or companies stated in your contract to which you provide any additional consent. In all other circumstances, the controller of your data will be Corporate and Security Solution Limited or companies stated in your contract.
Our personal data handling policy and procedures have been developed in line with the personal data protection laws that apply to us in the countries/regions in which we offer our good and services
When would we collect and process your personal data?
We will collect and process your personal data when
- you interact with us on our products or our services;
- you purchase goods and services from us;
- you and/or your nominating organisation contacts us to add you as a representative of your nominating organisation;
- you attend our conference meetings or marketing events.
Our website contains links to third-party websites, through which other users or third parties may gain authorized or unauthorized access to your personal data. The terms in this policy do not apply to the collection, processing or use of personal data that you communicate to the other users and/or third parties. It is in your best interest to acquaint yourself with the rules of personal data protection, and the protection of privacy applied by the other users and/or third parties. Since we cannot control the data you provide when accessing or using the links to third-party websites, or in other circumstances in which you communicate your personal data to the other users and/or third parties, we shall not be liable for any damage caused to you, other users and/or third parties, arising from the fact that you communicated your personal data, in relation to the use of our website.
What personal data do we collect?
The personal data we process includes:
- Date and time of your request,
- Your name,
- Email address,
- Country of residence,
- Gender,
- Language,
- Interests,
- IP address, and
- Any other personal data you provide.
What is the purpose of collection? How do we use the personal data and what is the legal basis for this use? In other words, what is the purpose and manner of the collection?
We collect the personal data listed for the following purposes:
- to establish and fulfill a contract with you, for example, if you make a purchase from us or enter into an agreement to provide or receive services. This may include verifying your identity, taking payments, communicating with you, providing customer services and arranging the delivery or other provision of products or services. We require this information in order to enter into a contract with you and are unable to do so without it;
- in accordance with the provisions of applicable law and regulation, which includes:
- the Personal Data (Privacy) Ordinance (Cap. 486),
- Regulations in force in Hong Kong Special Administrative Region (HKSAR)
- Personal Data Protection Act (Macao),
- European Union General Data Protection Regulation (EU GDPR),
- Personal Information Protection Law of the People’s Republic of China, and
- UK General Data Protection Regulation
- in order to protect CASSolution’s legitimate business interests, including but not limited to, use in connection with legal claims, compliance, regulatory and investigative purposes (including disclosure of such information in connection with legal process or litigation);
- with your express consent to respond to any comments or complaints we may receive from you；
- with your express consent to investigate any complaints received from you or from others, about our website or our products or services;
- we may use information you provided to personalise
- our communications to you;
- our website; and
- products or services for you, in accordance with our legitimate interests;
- to monitor use of our websites and online services. We may use your information to help us check, improve and protect our products, content, services and websites, both online and offline, in accordance with our legitimate interests;
- we may monitor any customer account to prevent, investigate and/or report fraud, terrorism, misrepresentation, security incidents or crime, in accordance with applicable law and our legitimate interests;
- we may use your information to invite you to take part in market research or surveys or marketing events.
We may send you direct marketing information in relation to CASSolution’s relevant products and services. Electronic direct marketing information will only be sent where you are our customer or have given your consent to receive it, or (where this is allowed) you have been given an opportunity to opt-out. You will continue to be able to opt-out of electronic direct marketing at any time by following the instructions in the relevant communication.
How do we limit the use of your personal data?
Your personal data are processed only on the basis of your approval in a free and express consent for the usage purposes stated in the consent available through our website. Your personal data shall be used in order to provide consent, reply to the queries that are submitted at our website.
CASSolution prohibits the use of personal data for any new purpose which is not or is unrelated to the original purpose when we collect your data, unless with your express and voluntary consent. You can withdraw your consent previously given by written notice, or email to info@cassolution.com.
With whom and where will we disclose your personal data?
We may disclosure your personal data with our subsidiaries and group companies and our service providers that we engage for the purposes of group administration to deliver products or services.
We may also share your personal data with the below third parties. They are required to keep your personal data confidential and secure and must only use your personal data as instructed by us.
- our professional advisors such as our auditors and external legal and financial and insurance advisors;
- marketing and communications agencies where youagreed to process your personal data in line with this Privacy Notice;
- market/ industry research companies;
- our suppliers, business partners and sub-contractors; and/or
- search engine and web analytics.
Personal data may be shared with government authorities and/or law enforcement officials if required for the purposes above, if mandated by law or if needed for the legal protection of our legitimate interests in compliance with applicable laws.
Personal data may also be shared with third party service providers who will process it on behalf of CASSolution for the purposes above. Such third parties include, but are not limited to, providers of website hosting, maintenance, call centre operation and identity checking.
In the event that our business or any part of it is sold or integrated with another business, your details will be disclosed to our advisers and those of any prospective purchaser and will be passed to the new owners of the business.
How do we ensure security of your personal data?
We endeavour to take reasonable measures to protect your personal data, prevent unauthorized access to and improper use of your personal data collected through:
- restricting access of personal data to relevant persons on a “need to know” basis;
- providing relevant training to the person who handle personal data properly. Given no system is impenetrable and no information provided over the internet can be guaranteed that the transmission and system are fully secure.
How long will we keep your personal data? Where is your personal data stored? How do we ensure the accuracy and duration of retention?
Your personal data may be transferred to, and stored outside Hong Kong and Macao.
We will not keep your personal data for any purpose longer than necessary to fulfill the original or a compatible purpose. In some instances, we are required to retain certain information by law and for as long as reasonably necessary to meet regulatory or accreditation requirements, resolve disputes, prevent fraud and abuse, or enforce our terms and conditions. Where this is the case, your personal data will only be processed for the relevant legitimate purpose and not used for marketing.
- Where you are a customer, we will keep your personal data for the length of any contractual relationship you have with us and after that for a period of 7 years to meet the legal regulation unless mutually agreed in the contractual documents;
- Where you are a potential customer and you have expressly consented to us contacting you, we will only retain your personal data for this purpose:
- until you unsubscribe from our communications; or, if you have not unsubscribed,
- while you interact with us and our content; or
- In the case of any contact you may have with our customer services team, we will retain your details for as long as is necessary to resolve your query and 3 years as per company retention policy.
We may retain your personal data for a time beyond the specified retention period, to allow for information to be reviewed and any deletion to take place. After it is no longer necessary for us to retain your personal data, we irreversibly delete your personal data according to our Data Retention Policy.
What are your rights in relation to your personal data?
Right to Access
You are legally entitled to access to your personal data from our database at any time. Modification or deletion of data shall be effected on the basis of an appropriate notice addressed to the contact identified on our website (info@cassolution.com) from you.
Right to Restrict Processing
You have the right to ask us not to process your personal data for marketing purposes. You can exercise your right to prevent such processing by checking certain boxes on the forms we use to collect your data, clicking the unsubscribe button on any communication we have sent to you or by contacting us.
Right to Erasure
Where you have consented to us using your personal data, you can withdraw that consent at any time.
Right to Rectification
If the information we hold about you is inaccurate or incomplete, you can notify us and ask us to correct or supplement it.
Right to Data Portability
You also have the right, with some exceptions and qualifications, to ask us to provide a copy of any personal data we hold about you.
Where you have provided your data to us and it is processed by automated means, you may be able to request that we provide it to you in a structured, machine-readable format.
Right to Object
If you have a complaint about how we have handled your personal data, you may be able to ask us to restrict how we use your personal data while your complaint is resolved. In some circumstances you can ask us to erase your personal data:
- by withdrawing your consent for us to use it;
- if it is no longer necessary for us to use your personal data;
- if you object to the use of your personal data and we don’t have a good reason to continue to use it; or
- if we haven’t handled your personal data in accordance with our obligations.
To exercise these rights, please contact our support team (info@cassolution.com).
In the event that you wish to lodge a complaint about how we have handled your personal data, please contact our support team (info@cassolution.com). We will then look into your complaint and work with you to resolve the matter.
If you still feel that your personal data has not been handled appropriately according to the law, you can contact the Privacy Commissioner for Personal Data, Hong Kong, and file a complaint with them.
Is there any transfer of personal data?
Yes, we will carefully transfer, or store certain personal data to Hong Kong and Macao. Your personal data may also be transferred out of the Hong Kong or Macao Special Administrative Region for the purpose of collecting such data, or for purposes directly related to it, and the transfer will comply with legal requirements.
It may also be processed by staff operating outside Hong Kong and Macao who work for us or for our suppliers, in which applicable safeguards or data protection law will be in place.
Minor
Our website does not plan or intend to obtain personal information of minors under 18 years of age. To respect the privacy of minors, minors under 18 years of age should not provide any personal information on this website or this application. We require that minors be supervised by their parents when browsing or using this website.
Cookies
We reserve the right to use cookies. A cookie is a group of data serving as your anonymous individual identifier that is sent to your browser by websites. Cookies are sent when you access a website,. They are stored in your computer and they serve to record information about your subsequent online visits. Therefore, after a cookie has been stored on your computer during your first access to a website, every time you return to the website it will look for its cookie in order to read the stored data. Since a cookie is an anonymous individual identifier, it does not contain or send any personal information to the website that stored it on your computer, but only enables faster and more efficient activation of information, data and settings previously communicated during access and use of the website. Your browser is set in such a way that each website can only access its own previously sent cookies, but not the cookies of other websites. The Options or Settings menu of your browser allows you to select an appropriate option for receiving cookies, even to disable them completely. However, disabling cookies completely will reduce the efficiency of some content available on some websites.
This Privacy Statement has been translated into Chinese. If there is any inconsistency or ambiguity between the English version and the Chinese version, the English version shall prevail.
Where can I find more information about CASSolution’s handling of my data?
Should you have any queries regarding this Privacy Notice, about CASSolution’s processing of your personal data or wish to exercise your rights you can contact CASSolution’s Privacy Team using this email address: info@cassolution.com.
If you are not happy with our response, please refer to the following for feedback:
- In Hong Kong , you can contact the Office of the Privacy Commissioner for Personal Data, Hong Kong,
- In Macao, you can contact the Office of Personal Data Protection
- In the United Kingdom, you can contact the Information Commissioner’s Office
- in the EEA, you can contact the supervisory authority in the European Union of your own nationality country
- anywhere else, you have the right to lodge your complaint with the relevant data protection regulator in the country/region where you are located.