Your Personal Data Privacy

PYPUN Group (“we” or “us”) respects your legal rights of privacy when collecting, storing, using and transmitting personal data and this Privacy Policy Statement (the “Statement”) explains our personal data privacy practices. It is our policy to comply with the requirements of the Personal Data (Privacy) Ordinance (Cap. 486) (the “Ordinance”) of the Laws of the Hong Kong Special Administrative Region of the People’s Republic of China (“Hong Kong”).

Please read the following carefully to understand our policy and practices regarding how your personal data will be treated. This Statement applies to the personal data held by us from time to time, including the data of the users of our website (the “Website”). This Statement may from time to time be revised or otherwise changed where we deem necessary.

If there is any inconsistency between the English and Chinese versions of this Statement, the English version shall prevail.

Throughout this Statement, the meaning of the term “personal data” is as defined in the Ordinance.

Kinds of Personal Data Held By Us

When you use the Website or other facilities provided by us, we may collect and hold your personal data. Kinds of personal data collected and held by us may include your name and other identification information, your mobile number, address, email address and other contact information, your interests and preferences, and information relating to your mobile device.

You are not obliged to supply the data, but if you do not, we may be unable to process your application or request, and some functionality or features of the Website may not be available.

If you are under the age of 13, you must ask your parent or guardian before providing any personal data to us.

Main Purposes For Which Personal Data Held By Us May Be Used

The main purposes for which we may use your personal data from time to time include the following:

• Recruitment and other human resources related purposes;
• Communicate with our investors and/or potential investors, our subsidiaries, associated and/or related companies;
• Comply with any law or court order binding on us, comply with any guidelines or codes of practice issued by regulatory or other authorities or governmental or law enforcement agencies with which we are required or reasonably expected to comply, and comply with any internal policies and measures relating to these compliance matters; and
• any other purpose(s) which has been agreed by or notified to you.

Disclosure and Transfer of Personal Data

We will take all reasonably practicable steps to keep your personal data confidential but we may disclose, transfer and exchange your personal data to and with other persons in or outside of Hong Kong, including the following:

• Any agent, contractor or third party service provider who provides administrative, telecommunications, computer and other services or support to us with respect to the operation of our business;
• PYPUN Group and any of its subsidiaries, associated and/or related companies; and
• Any person to whom we are under an obligation to make disclosure under the requirement of any law or court order binding on us or for the purposes of any guidelines or codes of practice issued by regulatory or other authorities or governmental or law enforcement agencies with which we are required or reasonably expected to comply.

Please refer to our Personal Information Collection Statement for further details on the use, disclosure and transfer of personal data.

Use of ‘Cookies’

When you use the Website, cookies will be stored in your computer. Cookies are small text files that are automatically created and stored on the web browser in your computer which can be retrieved by the Website. Cookies will collect and store information about your preferences, navigation pattern, login name, etc. We use cookies to track users’ visits to the Website to provide better user experience and customized services. We will not use cookies to collect any personal data from you. Most web browsers automatically accept cookies. You can disable the cookies on your web browser, but if you do, certain functionality or features of the Website may not be available.

Links to Other Websites

This Statement only applies to the Website. If you click on any advertisement or hyperlink linking to other website(s), the protection of your personal data privacy and your exposure to cookies on the other website(s) are not our responsibility. You are advised to refer to the privacy policy and practices of the relevant website.

Web Logs

When a user visits the home page of the Website, the visit will be counted and included in the total number of visits to the Website for statistical purpose. This information does not identify you as an individual. No personal data will be collected.

Security

We will take all reasonably practicable steps to keep your personal data protected against unauthorized or accidental access, processing, erasure, loss or use. Our protective measures may include providing training to the employees who handle personal data, restricting access to personal data and deploying encryption and other technology available in the market.

Use of Personal Data in Legal Proceedings

If it becomes necessary that we have to take action against you for any reason whatsoever including but not limited to recovering from you any money you owe us, you expressly agree that we can use your personal data in identifying and taking legal action against you.

Your Right To Access and Correct Your Personal Data

You may at any time request access to and correct personal data relating to you on our records. Please send your data access requests and data correction requests to us at the address below marking your communication “Confidential”. We may ask you to provide further information to enable us to verify that you have the right to make the relevant request. We may charge you a reasonable fee for handling a data access request.

Retention of Data

We will only keep your personal data for as long as necessary to fulfill the purposes for which the data was collected unless otherwise required or permitted by the Personal Data (Privacy) Ordinance. An example is we may retain the personal data to satisfy any applicable statutory or contractual obligations. Personal data which is no longer necessary will be destroyed.