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1. Statement of policy

 

We respect personal data privacy and are committed to complying with the requirements of the Personal Data (Privacy) Ordinance (PDPO).  In doing so, we strive to ensure compliance by our staff with the strictest standards of security and confidentiality.

 

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2. Statement of practice on personal data held by us

 

We may collect and hold personal data as an employer, a financial regulator and in performing our statutory functions under the relevant laws and regulations.  When we collect personal data from individuals, we will provide them with a Personal Information Collection Statement (PICS) on or before the collection in an appropriate format and manner.

 

Such personal data may include sensitive personal data.  The provision of personal data is generally voluntary unless otherwise specified.  A failure to provide the requested personal data, or the provision of inaccurate or incomplete information may result in us not being able to process your request, application, submission, enquiry, complaint or matter (as the case may be), or for us to perform our statutory and administrative functions under the relevant laws and regulations.

 

In performing our statutory and administrative functions under the relevant laws and regulations, personal data held by us may be disclosed to relevant courts, panels, tribunals and committees, and/or other local and/or overseas regulatory / government / judicial bodies as permitted or required under the law, pursuant to any regulatory / supervisory / investigatory assistance arrangements between us and other regulators (local / overseas), or persons engaged by us to assist us in the performance of our statutory functions. 

 

 

3. Personal data collected via forms / sections of our website

 

Without prejudice to our statement of practice on personal data held by us as mentioned above, generally:

 

(a) The information you provide in the "Contact Us" section or email/message/conversation to us via this website used by us to respond to or handle your enquiries, comments, suggestions or matter.  The personal data will not be used for any other purposes, disclosed or transferred without your consent, unless such use, disclosure or transfer is permitted or required by law.

 

(b) Personal data collected from job applicants who respond to a recruitment advertisement referral is used for consideration of the applicants' job application, and for recruitment related purposes, and will not be used for any other purposes, disclosed or transferred without your consent, unless such use, disclosure or transfer is permitted or required by law.

 

 

4. Information collected when you visit our website

 

(a) When you visit our website, a record of your visit is made as a "hit", which may show your Internet Protocol (IP) address and the pages you have visited.  No personally identifiable information is collected under this circumstance.  We use such information for statistical purposes, and for the purposes of maintaining and improving our website.

 

(b) When you browse our website, you should be aware that cookies are used.  Cookies are data files stored on your computer's hard drive.  Our website automatically installs and uses cookies on your browser when you access it.  The types of cookies used on our website are session cookies and persistent cookies.  The purpose of using cookies is to help us improve website performance and user's experience.

 

The cookies used in connection with our website does not collect or store personally identifiable information.  You may refuse to accept cookies on your browser by modifying the settings in your browser or internet security software.  However, if you do so, you may not be able to utilize or activate certain functions available on our website, if any.

 

 

5. Retention

 

Different retention periods apply to the various kinds of personal data collected and held by us.  We take all reasonably practicable steps to ensure that personal data will not be kept longer than is necessary for the fulfilment of the purposes (or any directly related purpose) for which the data is or is to be used, unless the retention is otherwise permitted or required by law.

 

In relation to the personal data collected via this website:

 

(a) Personal data provided under the "Contact us" section will be automatically deleted 365 days after any follow-up action has been completed, unless it is a complaint to us, in which case it will be retained for such period as may be necessary for the proper discharge of our functions.

 

(b) Personal data provided (whether submitted electronically or physically via forms available on this website or email) in any statement of personal information, annual return, notification on change of information and any other form of request for information is retained for such period as may be necessary for the proper discharge of our functions.

 

(c) In relation to personal data collected from job applicants who respond to a recruitment advertisement referral, where the application is unsuccessful, all such personal data will be destroyed after six months from the date of the application deadline.

 

 

6. Security

 

We take appropriate steps to protect personal data we hold against loss, unauthorized access, use, modification or disclosure.  All personal data you provide to us on this website is secured on our website.

 

 

7. Access and correction / enquiries

You have the right to request access to and correction of your personal data held by us about you in accordance with the provisions of the PDPO.  Please note that all data access requests should be made using the form specified by the Privacy Commissioner for Personal Data which is accessible from the following link "Data Access Request Form".

 

When handling a data access or correction request, we will check the identity of the requestor to ensure that he/she is the person legally entitled to make the data access or correction request.  We have the right to charge a fee for processing of any data access request.

 

We do not provide online facilities for you to delete or correct personal data held by us.

Any enquiries regarding personal data, or requests for access to personal data or correction of personal data, should be addressed in writing to our company:

 

The Data Privacy Officer
Mitsuba International Limited
Unit 703, 7/F., Alliance Comm. Building,

133 Connaught Road Central, CBD,
Hong Kong.

 

Note: Please note however, that where a complainant discloses information to us, and notwithstanding our policy that wherever possible the identity of complainants should not be revealed to outside parties, if the information is held or used for certain purposes related to law enforcement and regulation, we are exempt from the application of data protection principles 3 and 6 (use of personal data and access to personal data) by section 58 of the PDPO.  The information can then be used for these purposes whether or not a complainant gives authority.  The purposes include the prevention, preclusion or remedying (including punishment) of unlawful or seriously improper conduct, and protecting the public from financial loss arising from dishonesty, incompetence, malpractice or seriously improper conduct by persons concerned in the provision of financial services.

 

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Last update: 30 Dec 2021

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