The privacy of your personal information is important to us. This Statement describes how SGCL handles personal information collected through our websites, social media platform, products and/or services provided by our company operating in Hong Kong SAR (referred to as “Services”).
Our Services require some personal data to be collected.
In this Statement, your information is sometimes called “personal data” or “personal identifiable information” or “personal information”. We also sometimes collectively refer to handling, collecting, protecting or storing your personal information as “processing” such personal information. This Statement applies to any personal data provided to us, and any personal data created in connection with our Services.
By using our Services and providing personal information to us, you acknowledge that you have read this Statement, and subject to your explicit consent which we may separately seek from you as may be required by applicable law, you consent to the terms of this Statement (including international transfers as set out in this Statement to countries outside where you are located).
If you do not agree with the terms in this Statement and have concerns about the categories of personal data, we require from you, please do not provide any personal information to us without contacting us.
When you use our Services or register with our website, we may collect information about you including your name, your job title, your company’s name and its industry sector, your company’s address and your contact information (such as your name, current job title, name of employer, email address, Wechat ID and contact number). We may collect personally identifiable information about you either directly from you, or by combining information we collect and maintain through other means or as we may receive from publicly available sources such as social media or other third-party sites.
We may also collect personal data indirectly, such as using cookies. For more information on our use of cookies, please refer to Cookies section.
It is our policy that you are only required to supply us with the minimum scope of personal information that is necessary for us to complete your request and/or to provide you our Services (“Necessary Personal Information”). You may voluntarily provide us with additional personal information we ask for, which will help us to improve our Services and to better serve your needs. Failure to provide us with such additional personal information will not negatively affect your use of our Services.
We will not collect and process your sensitive personal data unless we have obtained your explicit consent as may be required under applicable law.
For Necessary Personal Information we collect, we will use it to complete your specific request and/or to provide you our Services, which may further include:
to provide our products/services, such as conducting pre-engagement acceptance checks prior to providing those products/services;
to communicate with you, such as responding to your enquiry, and determining the organisation that you work for and staying in touch with our business contacts;
to comply with any requirement of laws, regulation, or any government authority or agency, regulator, or a professional body of which we are a member; or to conduct any action to meet our obligations.
For personal information that is not Necessary Personal Information we collect, we will use it to improve our Services, to develop different functions of our products/services and to better serve your needs.
We will only use the personal information collected for the above purposes where we have a lawful basis for such processing, including obtaining any prior consent as may be required under applicable law.
We may send you communications including newsletter from time to time, upcoming events/seminars which may be of interest to you, and products or services that you request from us. Where we are legally required to obtain your consent to provide you with marketing materials, we will only send marketing materials if you have given consent for us to do so.
You may opt out of receiving marketing materials from us at any time by sending a message with “unsubscribe” in the subject line to "info@smartgcl.com"
Our website may link to third-party sites not controlled by us and which do not operate under our privacy practices. We assumes no responsibility for the information practices of these third-party sites that a user is able to access through ours. When you link to third-party sites, our privacy practices no longer apply. We encourage visitors to review each third-party site’s privacy policy before disclosing any personally identifiable information.
We have implemented generally accepted standards of technology and operational security in order to protect personally identifiable information from loss, misuse, alteration or destruction. Only authorised persons are provided access to personal information collected via the our Services; such individuals have agreed to maintain the confidentiality of this information.
Although we use appropriate security measures once we have received your personal data, the transmission of data over the internet (including by e-mail) is never completely secure. We endeavour to protect personal data, but we cannot guarantee the security of data transmitted to or by us.
Where a personal information security incident arises, we shall respond to the incident, assess the likely impact of the incident, and take necessary actions to bring the incident under control. Where necessary, we will report to the appropriate authority, notify you of the incident and provide relevant information, as may be required under applicable laws and regulations.
Cookies may be placed on your computer or device whenever you visit us online for our Services. Cookies are small text placed on our device that assist us in providing a more customised experience. If you are concerned about cookies, most browsers permit individuals to decline cookies. In most cases, you can refuse a cookie, however some functionality may be impaired. You can always delete cookies if you wish via your browser’s setting.
Your personal data may be transferred to, processed by third party service providers. We may transfer or disclose the personal data we collect to third party contractors, as well as other third parties, which may include providers of IT services, identity management, website hosting and management, data analysis, data back-up and archiving, security and storage services (including cloud service providers), event management, and other services with respect to the operation of our business. We use such third parties to support us in providing our Services.
When we transfer your personal data to third parties, we do so for the purposes stated under this Statement, for the administration and maintenance of websites and associated systems, and/or other internal or administrative purposes.
It is our policy to use only third party service providers that are bound to maintain appropriate levels of security and confidentiality and process personal information only as instructed by us pursuant to the contract between us. Subject to the foregoing, third party service providers may also use their respective subsidiaries and affiliates, and their own third party subcontractors that have access to personal data (sub-processors) to meet purposes of disclosure and/or transfer.
It is our policy to retain personal data only for as long as is necessary for the fulfilment of the purposes for which the data are to be used, or as required by law, regulation or professional standards and in order to establish, exercise or defend our legal rights.
We keep contact information (such as mailing list information) until a user unsubscribes or requests that we delete that information. If you choose to unsubscribe from a mailing list, we may keep certain limited information about you so that we may honour your request.
You may have certain rights under applicable laws in relation to the personal information we hold about you, including:
Right to update/correct your personal information which is inaccurate;
Right to request deletion of your personal information; and
Right to withdraw consent to processing your personal information (to the extent such processing is based on consent and consent is the only permissible basis for processing). Should your consent withdrawal be effective, we will no longer process the corresponding personal information. However, your decision to withdraw your consent will not affect the processing of personal information previously based on your authorization.
If you would like to exercise any of these rights, please contact us by email to “info@smartgcl.com”. We will treat your requests in accordance with applicable legal requirements.
We may need to update this Statement from time to time to comply with applicable law and regulations or other legitimate purposes. We may also separately advise you about the change. Subject to obtaining your explicit consent as may be required by applicable law, the new modified privacy statement will apply from that revision date. Therefore, we encourage you to review this Statement periodically to be informed about how we are protecting your information.