Privacy and Cookies Policy
Connect Communication Ltd. is committed to ensuring that your privacy is protected and our use of your personal information is governed by this Privacy Notice. On this site, “Connect Communication Ltd.”, “our” and “we” each mean all the HK SAR companies in the Connect Communication Ltd. group which collect and use your information in the manner set out in this Privacy Notice. Any reference to “you” or “your” refers to anyone whose personal information we process.
1. Introduction
Our use of your personal data will be governed by this Privacy Notice.
Connect Communication Ltd. is a controller for the personal information that it collects and uses about you. We will treat your personal information as confidential and in accordance with applicable data protection legislation and your personal information will only be shared with others in accordance with this Privacy Notice.
This Privacy Notice explains;
What personal information is
How we collect your personal information
The types of personal information we collect
How we use your personal information
The legal basis for processing your personal information
How we share your personal information
How long we keep your personal information
How we keep your personal information secure
Overseas transfers of your personal information
Your rights in relation to your personal information
How to make complaints and how to contact us
If there are any changes to the way in which your personal information is used, this Privacy Notice will be updated.
2. What is personal information
Personal information is any information that tells us something about you. This could include information such as name, contact details, date of birth, bank account details or any information about your needs or circumstances which would allow us to identify you.
Some personal information is classified as "special" data under data protection legislation. This includes information relating to health, racial or ethnic origin, religious beliefs or political opinions and sexual orientation. This information is more sensitive and we need to have further justifications for collecting, storing and using this type of personal information. There are also additional restrictions on the circumstances in which we are permitted to collect and use criminal conviction data.
Any references to personal information in this privacy notice will include personal data, and where relevant, special categories of personal data under the Hong Kong SAR Personal Data (Privacy) Ordinance- Cap.486 (the “Ordinance”).
3. What personal information do we collect?
We will collect your full name and contact details (such as phone number, email address and postal address) from you whenever you engage with us.
In addition, if we are providing a service to you, or on your behalf, where we are required to do so by law, we will collect information relating to your identity, which will be at least one form of photographic identification (such as a passport, a driving licence or an identification card) and one form of documentation with proof of your place of residence (such as a recent utility bill).
We will also confirm whether you have any relatives or close connections working at Connect Communication Ltd. so that we can consider potential conflict of interests and if identified how to manage these, in accordance with our statutory and regulatory obligations.
Depending on the service that we provide to you (or on your behalf) we may also collect additional personal information as detailed below.
We will collect a contact telephone number to get in touch with you about site/venue inspections, showcase events, offsite events such as conferences, meetings.
Where you engage with Connect Communication Ltd., we may collect information required to identify you to meet anti-money laundering and counter terrorist financing requirements.
Other
If you subscribe to receive research, news or other market updates from us, then in addition to the above we will collect details about the sector in which you work and the type of content that you would like to receive.
4. How we use your personal information
What is the legal basis of our data processing?
Under data protection legislation we are only permitted to use your personal information if we have a legal basis for doing so. We rely on the following legal bases to use your information;
Where we need information to perform the contract we have entered into with you
Where we need to comply with a legal obligation
Where the processing is necessary for us to carry out activities for which it is in Connect Communication Ltd.' legitimate interests (or those of a third party) to do so and provided that your interests and fundamental rights do not override those interests, including:
Processing that is necessary for us to promote our business, brands and products and measure the reach and effectiveness of our campaigns. – this will include sending you marketing information from time to time after you have engaged us to provide services or received services from us either which may be similar and of interest to you or where you have expressly indicated that you would like to receive such information. You have the right to opt out of receiving this information at any time.
Processing that is necessary to improve our knowledge of the training sector – this will include undertaking market analysis and research so that we better understand trends in the training sector and provide better knowledge along with more tailored and relevant services for our customers in the future.
Processing necessary for us to operate the administrative and technical aspects of our business efficiently and effectively – this will include: verifying the accuracy of information that we hold about you and create a better understanding of you as a customer; processing for administrative efficiency purposes such as where we outsource certain administrative functions to third parties who are specialise in such services; processing for network and information security purposes i.e. in order for us to take steps to protect your information against loss, damage, theft or unauthorised access or to comply with a request from you in connection with the exercise of any of your rights outlined below.
In more limited circumstances we may also rely on the following legal bases:
Where we need to protect your interests (or someone else's interests); and/or
Where it is needed in the public interest or for official purposes
We may process special categories of personal information and criminal conviction information in the following limited circumstances:
With your explicit consent, in which case we will explain the purpose for which the information will be used at the point where we ask for your consent.
Specific information on how your personal information will be used for the particular services you have requested from us is provided below.
We will share personal information with our regulators, governmental or quasi-governmental organisations, law enforcement authorities and with courts, tribunals and arbitrators as may be required from time to time in order to comply with our regulatory and legal obligations;
Where we use third party services providers who process personal information on our behalf in order to provide services to us. This includes IT systems providers and IT contractors as well as third party referencing or screening agencies for the purposes of the prevention and detection of crime.
We may share your personal information with any person working within the Connect Communication Ltd. Group on a need to know basis to ensure we are able to perform our obligations to you.
We will hold your personal information on our client management systems and use this to provide you with marketing information about similar services offered by Connect Communication Ltd. to those which you have engaged us to provide which we feel you might find useful from time to time. You have the opportunity to opt out of receiving this information at any time.
What happens if you do not provide information that we request?
We need some of your personal information to perform the services you have requested from us. For example:
where we are engaged in training your company staff members on your behalf we need to know your contact information so that we can update you with information requested by your staff and
We also need some information so that we can comply with our legal obligations. For example, we may need identity documents from you to meet our obligations to prevent fraud and money laundering.
If you do not provide the information required for these purposes, we will not be able to perform our contract with you and may not be able to provide services to you or continue to provide certain services to you. We will explain when this is the case at the point where we collect information from you.
5. How we keep your information secure
The security of information is very important to us and we have measures in place which are designed to prevent unauthorised access to your personal information including but not limited to:
Our client files are stored on our secure client management systems. Access is restricted on our client systems to those within the business who are required to have access to your information for legitimate business purposes.
Hard copy documentation is stored in locked cabinets.
We ensure access to personal information is restricted to Connect Communication Ltd. employees and workers or other persons working within the Connect Communication Ltd. Group on a need to know basis. Training is provided to any of those Connect Communication Ltd. employees and workers who need access to personal information.
6. For how long do we keep your personal information
The period for which we will keep your personal information will depend on the type of service you have requested from us. The retention period may be longer than the period for which we are providing services to you where we have statutory or regulatory obligations to retain personal information for a longer period, or where we may need to retain the information in case of a legal claim.
7. Overseas transfers of your personal information
We may transfer, store, or process your personal information in locations outside the HK SAR. Where the countries to which your personal information is transferred do not offer an equivalent level of protection for personal information to the laws of the HK SAR, we will ensure that appropriate safeguards are put in place.
We’ll use the safeguards:
Transfer it to a place outside HK with privacy laws that give the same protection as the HK. Learn more on the Hong Kong Legislation website for section 33 of Personal Data (Privacy) Ordinance (Cap. 486).
8. Your rights in relation to your personal information
You have a number of rights in relation to your personal information, these include the right to:
Be informed about how we use your personal information
Obtain access to your personal information that we hold
Request that your personal information is corrected if you believe it is incorrect, incomplete or inaccurate
Request that we erase your personal information in the following circumstances:
If Connect Communication Ltd. is continuing to process personal information beyond the period when it is necessary to do so for the purpose for which it was originally collected
If Connect Communication Ltd. is relying on consent as the legal basis for processing and you withdraw consent
If Connect Communication Ltd. is relying on legitimate interests as the legal basis for processing and you object to this processing and there is no overriding compelling ground which enables us to continue with the processing
If the personal information has been processed unlawfully (i.e. in breach of the requirements of the data protection legislation)
If it is necessary to delete the personal information to comply with a legal obligation
Ask us to restrict our data processing activities where you consider that:
personal information is inaccurate
our processing of your personal information is unlawful
where we no longer need the personal information but you require us to keep it to enable you to establish, exercise or defend a legal claim
where you have raised an objection to our use of your personal information
Request a copy of certain personal information that you have provided to us in a commonly used electronic format. This right relates to personal information that you have provided to us that we need in order to perform our agreement with you and personal information where we are relying on consent to process your personal information
Object to our processing of your personal information where we are relying on legitimate interests or exercise of a public interest task to make the processing lawful. If you raise an objection we will carry out an assessment to determine whether we have an overriding legitimate ground which entitles us to continue to process your personal information; and
Not be subject to wholly automated decisions which produce legal effects or which could have a similarly significant effect on you.
If you wish to obtain a copy of any of your personal data or if you believe that the personal data relating to you which the company collects and maintains is inaccurate, you may write or email Connect Communication Ltd. at the address below:
Connect Communication Limited at Rm A-4, Unit A, 2/F, Cheung Hing Industrial Building, 12P Smithfield, Kennedy Town, Hong Kong, S.A.R.
In accordance with the Ordinance, the Company has the right to charge a reasonable fee for the processing of any data access request.
9. Complaints and Contact Details
Complaints
If you have any complaints about the way we use your personal information please contact us at Rm A-4, Unit A, 2/F, Cheung Hing Industrial Building, 12P Smithfield, Kennedy Town, Hong Kong, S.A.R.
Contact details
If you have any questions, comments or requests regarding any aspect of this Privacy Policy, please do not hesitate to contact us by writing to information@connectcommunication.com at Rm A-4, Unit A, 2/F, Cheung Hing Industrial Building, 12P Smithfield, Kennedy Town, Hong Kong, S.A.R.
10. The use of cookies by Connect Communication Ltd.
What is a cookie?
A cookie is a small text file that is downloaded onto your computer when you visit certain websites and allows a website to recognise a user's computer. Cookies are used to help users navigate websites more efficiently and to perform certain functions, as well as to provide information to the owners of the website.
What Are Cookies
As is common practice with almost all professional websites this site uses cookies, which are tiny files that are downloaded to your computer, to improve your experience. This page describes what information they gather, how we use it and why we sometimes need to store these cookies. We will also share how you can prevent these cookies from being stored however this may downgrade or 'break' certain elements of the sites functionality.
For more general information on cookies, please read "What Are Cookies".
How We Use Cookies
We use cookies for a variety of reasons detailed below. Unfortunately in most cases there are no industry standard options for disabling cookies without completely disabling the functionality and features they add to this site. It is recommended that you leave on all cookies if you are not sure whether you need them or not in case they are used to provide a service that you use.
Disabling Cookies
You can prevent the setting of cookies by adjusting the settings on your browser (see your browser Help for how to do this). Be aware that disabling cookies will affect the functionality of this and many other websites that you visit. Disabling cookies will usually result in also disabling certain functionality and features of this site. Therefore it is recommended that you do not disable cookies.
The Cookies We Set
Email newsletters related cookies
This site offers newsletter or email subscription services and cookies may be used to remember if you are already registered and whether to show certain notifications which might only be valid to subscribed/unsubscribed users.
Surveys related cookies
From time to time we offer user surveys and questionnaires to provide you with interesting insights, helpful tools, or to understand our user base more accurately. These surveys may use cookies to remember who has already taken part in a survey or to provide you with accurate results after you change pages.
Forms related cookies
When you submit data through a form such as those found on contact pages or comment forms cookies may be set to remember your user details for future correspondence.
Third Party Cookies
In some special cases we also use cookies provided by trusted third parties. The following section details which third party cookies you might encounter through this site.
This site uses Google Analytics which is one of the most widespread and trusted analytics solution on the web for helping us to understand how you use the site and ways that we can improve your experience. These cookies may track things such as how long you spend on the site and the pages that you visit so we can continue to produce engaging content.
For more information on Google Analytics cookies, see the official Google Analytics page.
From time to time we test new features and make subtle changes to the way that the site is delivered. When we are still testing new features these cookies may be used to ensure that you receive a consistent experience whilst on the site whilst ensuring we understand which optimisations our users appreciate the most.
We also use social media buttons and/or plugins on this site that allow you to connect with your social network in various ways. For these to work the following social media sites including; LinkedIn, Facebook, Twitter will set cookies through our site which may be used to enhance your profile on their site or contribute to the data they hold for various purposes outlined in their respective privacy policies.
More Information
Hopefully that has clarified things for you and as was previously mentioned if there is something that you aren't sure whether you need or not it's usually safer to leave cookies enabled in case it does interact with one of the features you use on our site.