101 Studio shall fully comply with its obligations under the requirements of the Personal Data (Privacy) Ordinance (Cap.486) and Personal Data (Privacy) (Amendment) Ordinance 2012 (collectively the “Ordinance”) of the Hong Kong Special Administrative Region of the People’s Republic of China. 101 Studio shall at all times respect the confidentiality of and endeavour to keep safe any and all Personal Data collected and/or stored and/or transmitted and/or used for or on behalf of 101 Studio.
General Statement of Policies and Practices on Personal Data
Collection of Personal Data
(a) For the purpose of carrying on 101 Studio’s business, you may be requested to provide your Personal Data when you use our services at 101 Studio, when you submit any comments or feedback to us, when we ask you to verify your identity.
(b) We will ask you to provide your Personal Data including name, contact number, email address, gender, month of birth, age and the district / city / country where you normally reside.
(c) We will collect Personal Data on a lawful, open and fair basis.
Purpose for Collection of Personal Data
101 Studio will collect and may use your Personal Data for the following purposes :
(a) the provision of 101 Studio’s products and/or services to you;
(b) carrying out your instructions or responding to your enquiry;
(c) forming part of 101 Studio’s customer data base necessary for the operations carried on by us;
(d) transferring or sharing your Personal Data with our affiliates in other countries and territories for the purposes of carrying out (a), (b) and (c) above in this section;
(e) general security reasons; and
(f) any purposes related to and/or for the furtherance of (a) to (e) above.
Without your consent, we shall not use your Personal Data for purposes other than those specified above.
101 Studio will take all practicable steps to ensure that Personal Data collected is accurate. Please endeavour to provide 101 Studio with accurate Personal Data upon subscription of 101 Studio’s services and where there are any changes to your Personal Data, please inform us as soon as possible.
Personal Data Sharing, Transfer and Disclosure
All Personal Data held by 101 Studio will be kept confidential but 101 Studio may, where sharing, transfer or disclosure is necessary to satisfy the purpose, or a directly related purpose, for which the data was collected provide such information to the following parties:
(a) Any person or company who is acting on behalf of 101 Studio as agent in respect of the purpose or a directly related purpose for which the data was provided.
(b) Personal Data may also be disclosed to any person or persons pursuant to any statute or as required by any court of law in Hong Kong, provided such person or persons are able to prove the required right/authority to access such information.
(c) We may transfer or share your Personal Data to/with our affiliates.
(d) We will not sell your Personal Data to any person or company.
(e) We will not share, transfer or disclose your Personal Data to/with any person or company for direct marketing purposes.
Access and Correction
You may check whether we hold any of your Personal Data and, if so, may request
(a) access (i) by sending an e-mail to the Data Protection Officer at firstname.lastname@example.org; or (ii) by mailing us at 28/F, Futura Plaza,111-113 How Ming Street, Kwun Tong, Kowloon.
(b) corrections by sending an e-mail to the Data Protection Officer at email@example.com.
We will take reasonable steps to verify your identity before granting access or permitting corrections to your Personal Data. We will endeavour to respond within 40 days of your request in compliance with the Ordinance. We will charge a reasonable fee to cover our administrative costs when you request access to your Personal Data. We will comply with your request after the imposed fee is paid. We will not charge a fee for corrections to your Personal Data. Should we refuse your request for access or correction, reason(s) will be given. You may object to our reason(s) for our refusal to grant you access or correction.
We strive to ensure that your Personal Data will be protected against unauthorised or accidental access, processing or erasure or other use. We maintain this commitment to data security by implementing appropriate physical, electronic and managerial measures to safeguard and secure your Personal Data.
Retention of Personal Data
Your Personal Data will only be retained for as long as is necessary to fulfill the original or directly related purpose for which it was collected, unless this is contrary to any applicable laws.