Joy Square Limited ("JSL") recognizes and understands that customers and website visitors are concerned about the privacy of information. JSL pledges to comply with the requirements of the Personal Data (Privacy) Ordinance (Cap. 486) of the Laws of Hong Kong Special Administrative Region.
Eureka Nova is a programme of and operated by Joy Square Limited. In operating Eureka Nova, JSL pledges to comply with the requirements of the Personal Data (Privacy) Ordinance (Cap. 486).
2 Collection of Information
You may be invited to provide to JSL and/or Eureka Nova your personal data on JSL's and/or Eureka Nova’s website(s) or through other media on a voluntary basis for different purposes at different times. If you are under the age of 18, you should obtain consent from your parent or guardian before you provide JSL and/or Eureka Nova with your personal data.
3 Log Files
When you visit JSL's and/or Eureka Nova’s website(s), the servers of JSL will only collect data relating to your visits (including but not limited to your IP address, domain name, browser type and access time) but will not collect your personal data.
Cookies are alphanumeric identifiers that we transfer to your computers, mobile phones or other devices through your web browser for record-keeping purposes. Some cookies allow us to make it easier for you to navigate JSL’s and/or Eureka Nova’s website(s) or mobile application(s), while others are used to enable a faster log-in process, or to allow us to store and track information about your interests and preferences at JSL’s and/or Eureka Nova’s website(s) or mobile application(s).
We may also engage third parties to track and analyse non-personally identifiable data from the website(s) or mobile application(s). We use the data collected by such third parties to help us administer and improve the quality of JSL’s and/or Eureka Nova’s website(s) or mobile application(s) and to analyse usage of the same. Such third parties may combine the information that we provide about you with other information that they have collected. You can edit your browser settings to disable cookies but to do so you may not be able to utilize certain functionality of the website(s) of JSL and/or Eureka Nova.
We may also collect information regarding your IP address, browser type, domain name and access time. This information is used for JSL’s research purposes. This is unrelated to and separate from your personal data. In rare instances, IP addresses may be used to assist in deterring and/or preventing abusive or criminal activity on the website.
If you interact with JSL and/or Eureka Nova on social media platforms (for example if you “Like” JSL’s and/or Eureka Nova’s Facebook page), JSL can interact with you and send you messages via these platforms. JSL will interact with you in accordance with the social media platform’s rules but we are not responsible for how the platform operators collect and handle your personal data. We are not responsible for what third parties post on our social media accounts.
5 Kinds of Information Collected
For the different purposes in the course of conducting JSL's business, you may be required to provide to JSL and/or Eureka Nova your personal data, which may include your name, gender, date of birth, e-mail address, mailing address, contact number, membership number, age, marital status, family status, educational level, occupation, username and password, etc. Details of personal data and information to be collected will be set out in the relevant Personal Information Collection Statement ("PICS") provided to you upon collection of such data and information.
6 Main Purposes and Uses of Information Collected
JSL will use your personal data for specific purposes identified in the PICS provided to you when your personal data is collected.
In addition, JSL may use your personal data for the following purpose:
- (a) identifying and verifying your identity ;
- (b) communicating with you in respect of your use of JSL’s and/or Eureka Nova’s services, products, mobile application(s) and/or website(s) (as the case maybe);
- (c) daily operation and administration including but not limited to account creation and maintenance;
- (d) monitoring and analysing usage of its services, products, mobile application(s) and/or website(s) (as the case maybe) to help the further development and improvement of its services, products, mobile application(s) and/or website(s);
- (e) research and development in relation to customer behavior;
- (f) information management and database administration;
- (g) detection, investigation and/or prevention of activities that may violate our policies or maybe illegal;
- (h) collection or recovery of any debt owed by you to JSL.
7 Accuracy of Information
You may be requested to provide to JSL and/or Eureka Nova certain personal data (particularly relating to your contact information) for specific services. If you fail to provide or update accurate information as requested for each specific service, the provision of such services by JSL and/or Eureka Nova may be affected.
8 Retention of Information
JSL will retain your personal data for a period no longer than necessary for the fulfillment of the purposes for which they are or are to be used. If you are a subscriber of JSL and/or Eureka Nova services, your personal data will be retained for a reasonable period after termination of your subscription for verification and audit purposes. The above is subject to any legal, statutory, regulatory or accounting requirements.
9 Third Party Merchants
JSL may have on-line stores or some services and/or products which are hosted in the website(s) of JSL and/or Eureka Nova but are operated by third party merchants. If you provide your personal data to the third party merchants in order to use, order or receive any services and/or products from the third party merchants, please note that your personal data is beyond the control of JSL and thus is outside the scope of protection afforded by JSL.
10 Third Party Websites
11 Service Providers
12 Security of Information
The physical records of your personal data will be stored in secured places with restricted access. The electronic records of your personal data will be stored in the servers of JSL located in secured places and protected by adequate IT security measures (e.g. encryption for transmission of sensitive data through the internet in appropriate cases). Only authorized personnel of JSL (who have been trained to handle your personal data properly and bound by a duty of confidentiality) will have access to these records and servers on a "need-to-know" and "need-to-use" basis.
No data transmission over the internet or any other public network can be guaranteed to be completely secure, and privacy cannot be assured in your communications to us. You are encouraged to protect against unauthorized access to your password. You are advised to sign out from your account when finished particularly when using a shared computer.
JSL may disclose your personal data as required by law, by any government departments, regulatory authorities, enforcement agencies and courts of competent jurisdiction. JSL excludes all liability for disclosure of your personal data in this manner.
14 Use in Legal Proceedings etc.
If it becomes necessary for JSL to take action against you for recovering from you the debt you owe to JSL, you agree that your personal data can be used by JSL in identifying and taking legal action against you.
15 Access and Correction of Information and Withdrawal of Consent
You have the right to request in writing to the Personal Data Privacy Officer of JSL :
- a. for access to your personal data held by JSL (if any);
- b. require JSL to correct your personal data that is inaccurate (if any); and
- c. withdraw your consent to the use of your personal data (such withdrawal may, however, affect our services to you).
All such requests will be handled promptly in accordance with the requirements of the Personal Data (Privacy) Ordinance. JSL may charge a reasonable fee for processing your data access request.
16 Direct Marketing
We cannot use your personal data for direct marketing purposes without your consent. Subject to your consent, we may use your personal data for direct marketing in accordance with the PICS provided to you upon collection of your personal data. You may withdraw your consent any time in by writing to the Personal Data Privacy Officer of JSL at 9C, 9/F, KOHO, 73-75 Hung To Road, Kwun Tong, Kowloon, Hong Kong or by email at email@example.com.
18 Change of Control
If you have any questions or wish to access or correct your personal data or withdraw your consent to the use of your personal data held by JSL, please contact the Personal Data Privacy Officer of JSL at:
- Joy Square Limited
- 9C, 9/F, KOHO,
- 73-75 Hung To Road,
- Kwun Tong, Kowloon, Hong Kong
- Personal Data Privacy Officer
- (Marked Confidential)
, or by email at firstname.lastname@example.org.
20 English Version