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Welcome to the official website of Aequa and Company (H.K.) Limited at www.aequaandco.com (hereinafter referred to as “this Website”).  This Website is operated and managed by Company (H.K.) Limited, situated at Flat 610, 6/F., Block A, Focal Industrial Centre, 21 Man Lok Street, Hung Hom, Kowloon, Hong Kong (hereinafter referred to as “we” or “the Company”).  We respect your privacy rights.  During our collection, retention, use and transmission of your personal data, our staff and/or agent will thoroughly and strictly abide by the principles and rules of Cap 486 “Personal Data (Privacy) Ordinance” (hereinafter referred to as “the Ordinance”) of the laws of the Hong Kong Special Administrative Region, and endeavour to ensure the safety and confidentiality of your personal data.  This privacy protection notice is intended to explain our policy in protecting your personal data and privacy (hereinafter referred to as “the Privacy Notice”).   

Collection of Personal Data

Personal data is provided on a voluntary basis.  There is no need for you to provide us with any information, but the non-provision of personal data can lead to our failure to provide you with services.  If you choose to provide us with personal data, we may, at the time of your agreement to use our services, collect, process and retain the personal data in whole or in part, including but not limited to the following:
1. Your name;
2. Gender, age, date of birth, nationality, occupation;
3. Contact details, such as email address, mailing address, billing address, telephone number, hyperlink to social media etc.;
4. Information for checking of personal identity, including the type and the number (such as your Hong Kong Identity Card number and your passport number) of personal identification document as well as other relevant data;
5. The IP address of your computer or mobile device, instant location data, browser settings, browsing records and/or other internet records and information.

Retention of Personal Data

The Company will retain Your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use Your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies. The Company will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of Our Service, or We are legally obligated to retain this data for longer time periods.

Use of Personal Data 

Your personal data can be used for, including but not limited to, the following purposes:
1. To process your application for opening of account;
2. To provide you with services;
3. To verify your identity;
4. To process your orders, issue you with invoices, to deliver the order and direct marketing of our services;
5. To publicize and promote any service that we provide to you, such as sending you information on discounts and promotions;
6. Direct marketing of products and services of the business partners of the Company (for details, please see “Direct Marketing” below)
7. To process your complaints and account enquiries;
8. To conduct our audit;
9. To implement any guidelines, instructions, orders or requirements issued by any legal, supervisory, government, taxation, law enforcement or any other organizations in Hong Kong or beyond;
10. To facilitate correspondence and all liaison between you and the Company.

Transfer of Personal Data 

Your information, including Personal Data may be transferred to and maintained on servers located outside of your state, province, country where the data protection laws may differ from those in your jurisdiction. You nevertheless consent to this Privacy Notice by agreeing to voluntarily submit your personal information to us. The Company will take all reasonable steps to ensure that your data is secured to the extent of the Ordinance.  

Disclosure of Personal Data

Under the following circumstances, your personal data may be disclosed to a third party:
1. The Company will disclose the relevant personal data in accordance with the guidelines, instructions, directions or request issued by any legal, supervisory, government, taxation, law enforcement or other organization in Hong Kong or beyond;
2. Under your agreement, to be used for direct marketing (for details please see “Direct Marketing” below);
3. Your personal data will be provided to our associated companies, the sellers providing or transporting the goods/services, the contractors, agents, transportation companies or other services providers in order to provide services;
4. Your personal data will be disclosed to any person under the duty of confidentiality to the Company, including members of our group of companies, IT consultants, auditors, accountants or lawyers etc. who have undertaken to keep such information confidential;  

5. At your request, your personal data shall be disclosed to your authorized representative or lawyer etc.

Direct Marketing 

The Company shall use your personal data for direct marketing of the Company or any third- party organizations only when exempted by the Ordinance or if we have received your written consent.  To this end, your personal data may be provided to third party organizations for direct marketing.  However, without exemption by the Ordinance or prior to receiving your written consent, the Company shall not use and/or provide your personal data in the way mentioned above.
If you do not wish to have your personal data used for direct marketing purposes, please send us your request by emailing to info@aequaandco.com.

Links to Third Party Website

The Privacy Notice is applicable to this Website only.  Our website may contain links to other sites and pages which are operated by third parties.  The Company has no control over the content of the linked websites or the way in which the operators of those websites deal with your personal data.  After leaving this Website, the information provided to any other third-party website shall be beyond the control of the Company, and you shall be responsible for the risks caused by your browsing or use of third-party websites.  You should review the privacy policy for those third-party websites to understand the ways in which your personal data may be used by those third parties.

Access to and Correction of Your Personal Data

Generally, and according to the “Personal Data (Privacy) Ordinance”, you have the right to access to and correct your personal data.  In order to protect your privacy and personal data, the Company shall verify your identity with reasonable steps before providing personal data for your perusal.  If you find the data to be incorrect, incomplete or outdated, you can request us to correct and/or supplement the data.  In order to process the relevant request for access to and correction of personal data, the Company has the right to levy a reasonable charge.
Please send us the above request by emailing to info@aequaandco.com. This paragraph is to be read in conjunction with “Rights of users” hereinbelow. 

Collection of data of minors (persons under the legal age of 18)

Our Services are not catered to anyone under the age of 18, and therefore, we would not knowingly collect personal data of minors. If you are the parent or legal guardian of a minor and you believe that your minor has accidentally accessed our website and provided us with personal data, please contact us at info@aequaandco.com immediately. 

Rights of users

You have the right to submit access request to us and request for a copy of any personal data we hold concerning you. We will consider your request accordingly. 

You have the right to rectify any information we hold on you that may be inaccurate or incomplete.

You have the right to request that we erase our data in certain circumstances, such as when the data is no longer necessary, the data was unlawfully processed, or it no longer meets the lawful ground for which it was collected. However, please note that the use of your data may be required to facilitate our provision of services to you and your request to erase your data may restrict our ability to provide services to you. 

You have the right to request that we limit the way we use your personal data. However, please note that the use of your data may be required to facilitate our provision of services to you and your request to limit our use of your data may restrict our ability to provide services to you. 

If you have provided personal data to our data controller by way of a contract or consent, you may request to obtain and reuse your personal data for your own purposes. By making such request, you hereby accept all liability and risks in allowing others access to such information, and the requested data shall not include any data/information we created based on the data you provided, such as a user profile. This right does not apply if we have legitimate interest or public interest to process your personal data, or if the subject personal data is pseudonymised.

You have the right to object the processing of your personal data that we have collected on direct marketing, and we would only continue to process your personal data if we determined that we have a compelling reason for doing so.  

You have the right to request a review of the processing of your personal data if you have reasonable grounds to believe that we have not followed the applicable rules and/or regulations. 

To exercise one or more of the above rights, you may be required to sign a declaration. 

Amendment of Terms

The Company has the right to change and/or amend the terms of the Privacy Notice from time to time without providing prior notice to you.  You should regularly browse this Website to peruse any change and/or amendment of any terms.  If you continue to use our services after the change and/or amendment of the Privacy Notice, your effective and irrevocable acceptance and agreement to be bound by the changed and/or amended terms shall be deemed.

Use of Cookies

In order to enhance the functions of and for your convenience in browsing this Website, some webpages have Cookies.  This type of text files will be placed in the web browser of your computer to store your personal preferences.  Cookies will not provide the Company with your personal data, unless you choose to directly provide this Website with such data.  However, when you choose to provide this Website with your personal data, such data will be linked with the information stored in the Cookies.  The default setting of most web browsers will accept Cookies.  You can change the settings of your web browser to reject Cookies, or to notify you before your web browser accepts Cookies.  If you choose to reject Cookies, certain functions of this Website may become inoperable.  

Contact Method

If you would have any queries or comments on the Privacy Notice of this Website, you are welcome to contact the Company at info@aequaandco.com