General Privacy Notice - HSL
HACTL Solutions Limited ("HSL", "we", "our" or "us") is committed to protecting the privacy, confidentiality and security of the personal information we hold by complying with the requirements of Hong Kong’s Personal Data (Privacy) Ordinance. We are equally committed to ensuring that all our employees and agents uphold these obligations.
This privacy notice explains what information we gather about customers and various other individuals ("you" or "your"), what we use that information for, the purposes for which that information is used and who we give that information to. It also sets out your rights in relation to your information and who you can contact for more information or queries.
Click on the links below to take you to the more detailed sections of this privacy notice:
- Who this privacy notice applies to and what it covers
- What information we collect
- How we use information about you
- Who we disclose your personal information to
- How long we keep your personal information
- Protection of your personal information
- Your rights and how to contact us
- Changes to this privacy notice
What it covers and who this privacy notice applies to
We recognise the importance of protecting the privacy of personal information and handling personal information in an open, transparent and secure manner.
This privacy notice sets out how we will collect, handle, store, share and protect information about you.
In this privacy notice, we may refer to information about you as your "personal information". We may also sometimes collectively refer to handling, collecting, protecting and storing your personal information as “processing” such personal information.
What information we collect
We typically collect or obtain personal information because you give it to us (for example, physically or through the specific webpages of www.HactlSolutions.com that provide a link to this notice ("our Website" or "this Website")), or because other people give that information to us (for example, carriers who engage us or our third party service providers that we use to help operate our business and run our Website), or because it is disclosed on publicly available sources.
We also usually collect or obtain personal information from you because we observe or infer that information about you from the way you interact with us or others.
The personal information that we collect or obtain typically includes, but is not limited to: your name; age; date of birth; gender; e-mail address (including your business and personal e-mail addresses); company by which you are employed; home and business address; telephone/mobile/fax number; other contact details; country of residence; family circumstances (for example your marital status); employment and education details (for example, the organisation(s) you work for, your job title and the name of the educational establishments that you attended); identity card numbers; Chinese Character Code; passport numbers; financial and tax-related information (for example, your income assets and tax residency where such information appears in any documentation your provide to us); lifestyle and social circumstances (for example, where we would like to invite you to an event that may be of interest to you); postings on any blogs, forums, wikis and any other social media applications and services that we provide; IP address; browser and device type; language; access times and duration; details of how you like to use our Website; details of how you like to interact with us and other similar information.
In some cases, we will also collect personal information about you indirectly from third parties such as: (i) carriers who engage our services; (ii) third party service providers that help us to operate our Website; (iii) recruitment agencies that you use to apply to HSL; (iv) background check providers; and (v) publicly available sources.
Note that if you refuse or are otherwise unable to supply your personal data as requested, we may be unable to provide you with goods and service or to process your application, where use of your personal data is required.
How we use personal information about you
We will use your personal information in connection with the HSL Group (means HSL, and its subsidiaries and affiliates) ’s business. In particular, we will use your personal information for the purposes or, in connection with:
• assisting us in managing external service providers;
• undertaking recruitment activities, such as processing your employment application, determining the suitability of your qualifications, checking for any existing or potential conflicts of interest or any other restrictions which may otherwise restrict or prevent employment with any members of the HSL Group;
• undertaking matters relating to or in connection with your employment with any members of the HSL Group, including for the purposes of payroll, benefit, administration, transfer and other career -related matters, staff planning, transfer of employment and secondment, facilitating performance appraisals, promotion and career development activities, making tax returns, review of employment decisions and providing references to future employers; managing our HR records and updating our employee database;
• where relevant, managing and making available personal information within the HSL Group;
• corresponding and managing your relationship with the HSL Group;
• applicable legal or regulatory requirements and requests and communications from governmental departments or public or judicial authorities;
• financial accounting, invoicing and risk analysis purposes;
• prudent operational management (including credit and risk management, insurance, audit, training, statistical analysis for business, security purposes, any other supporting and administrative services and similar administrative purposes);
• prudent IT management (including management of our IT resources, infrastructure and business continuity);
• business development purposes, including direct marketing of HSL’s services to customers through the sending of promotional or marketing emails, articles or materials in accordance with the paragraph on “Use of personal information in direct marketing” below;
• services we receive from our professional advisors, such as lawyers, accountants and consultants;
• considering, assessing and entering into, any transaction involving part or all of the business, shares or assets of any member of the HSL Group;
• protecting our rights and those of our customers and clients;
• meeting our corporate and social responsibilities; and
• any other purposes directly related to any of the above.
Use of personal information collected via our Website
We generally use personal information collected via this Website:
• to manage and improve any services provided via our Website;
• to manage and improve our Website (including drawing up statistics on the usage of our Website);
• to manage and respond to any request you submit through our Website; and
• to help us learn more about you, the products and services that you receive, and other products and services that you might be interested in receiving.
Use of personal information in direct marketing
In addition to the purposes set out above, we intend to use your personal information in our records (including name, address, contact numbers and email address) in direct marketing and we may not so use the information unless we have received your consent. We would like to contact you about our products and services relating to our professional services (including IT project management services, professional services on requirement analysis/software design/development/implementation and user training services) and events organised by us on the foregoing services.
If you do not agree to such use of your personal information in direct marketing, please indicate your objection in the acknowledgement form that may be provided to you.
If you do not want to continue receiving any marketing materials from us, you can click on the unsubscribe function in the relevant direct marketing communication or e-mail info@HactlSolutions.com.
Who we disclose your personal information to
In connection with one or more of the purposes outlined in the "How we use personal information about you" section above, we generally disclose details about you to:
• our direct and indirect subsidiaries, holding companies and associated companies or affiliates of the HSL Group;
• professional advisors and third parties that provide services to us (such as market research companies, printing, mailing, publicity services providers, IT systems providers, hosting providers, payroll providers, recruitment, background check providers, IT support providers, consultants (including lawyers and accountants) and online platforms for downloading our mobile software applications;
• airlines, other air cargo terminals, freight forwarders, Hong Kong Association of Freight Forwarding And Logistics Limited, and the International Air Transport Association;
• the Hong Kong Airport Authority and any other competent governmental and public or judicial authorities in Hong Kong or overseas (including customs authorities, tax authorities, law enforcement agencies and any other national and/or international regulatory or enforcement body or courts or other form of tribunal); and
• any actual or proposed purchaser of the business or part of the business of the HSL Group and its legal advisers or, in the case of a share acquisition, the purchaser or subscriber of shares in any HSL Group company and its legal advisers.
Please note that the recipients of your personal information referenced above may be based in or outside Hong Kong. This means your personal information may be transferred to countries whose laws may not provide the same level of data protection as Hong Kong.
In such cases, we will ensure that there are adequate safeguards in place to protect your personal information that comply with our legal obligations.
How long we keep your personal information
We will hold your personal information on our systems for as long as is necessary to fulfil the purpose for which it was collected or to comply with legal, regulatory or internal policy requirements.
Protection of your personal information
We use a range of physical, electronic and managerial measures to ensure that we keep your personal information secure, accurate and up to date. These measures include:
• education and training to relevant staff to ensure they are aware of our privacy obligations when handling personal information;
• administrative and technical controls to restrict access to personal information on a ‘need to know’ basis;
• technological security measures, including fire walls, encryption and anti-virus software; and
• physical security measures, such as staff security passes to access our premises.
Although we use appropriate security measures once we have received your personal information, the transmission of data over the internet (including by e-mail) is never completely secure. We endeavour to protect personal information, but we cannot guarantee the security of data transmitted to us or by us.
Your rights and how to contact us
In general, and subject to certain exemptions, you have a right to:
• request access to your personal information by completing the “Data Access Request Form” specified by the Privacy Commissioner for Personal Data from time to time;
• request the correction of your personal information; and
• be given reasons if a request for access or correction is refused.
To exercise any of your rights, or if you have any other questions about our use of your personal information, please e-mail our Corporate Communications Officer by email at info@HactlSolutions.com or write to the following address:
HACTL Solutions Limited
Room 410, 4/F North Office Block
Super Terminal 1
Hong Kong International Airport
You may also use these contact details if you wish to make a complaint to us relating to your privacy.
Changes to this privacy notice
This notice was last updated on October 2018.
The governing version of this Privacy Notice is the English version and shall prevail when there are inconsistencies between the English version and any Chinese version. This Privacy Notice does not extend to third-party websites that may be linked from our Website, or from any other broadcast affiliated with us.
It may be subject to amendments. Any future changes or additions to the processing of personal information as described in this notice affecting you will be communicated to you through an appropriate channel, depending on how we normally communicate with you.