We respect your right to privacy and will only process personal data you provide to us in compliance with the requirements of the Personal Data (Privacy) Ordinance in Hong Kong or the Personal Data Protection law (Law No. 8/2005) in Macau, as applicable in your jurisdiction.
We do not and will not knowingly collect information from any unsupervised person under the age of 18. If you are under the age of 18, you must not use this Website or submit any personal data to us through whatever means unless you have the consent of, and are supervised by, a parent or guardian.
What Data do We Collect?
Depending upon your use of Our Site, We may collect some or all of the following data:
- Your Name
- Your E-mail Address
- Any other data, information, work in any format you submit to us through our website, e-mail or any other channel. Examples include but not limited to business name, job title, profession, telephone number etc which are sent to us as Request Description in Online Inquiry or Job Application with e-mail.
How do We Collect Your Personal Data?
In addition, we may collect anonymised details about visitors to our Website for the purposes of aggregate statistics or reporting purposes. However, no single individual will be identifiable from the anonymised details that we collect for these purposes.
We may also collect the personal data, including your name and email address as stipulated in the respective forms and/or other documents (in whatever format) when you submit the same to us.
In some cases, the collection of data may be a statutory or contractual requirement, and We will be limited in the products and/or services. We can provide you without your consent for Us to be able to use such data.
Personal data may also be collected from third parties who have your consent to pass your details to us. You understand and confirm that your provision of personal data is done voluntarily.
By submitting the personal data whether through the Website or other means, you warrant and confirm that you have the proper authorization to make the submissions, and all the information submitted is real and correct.
If you are under 18 years of age, you shall consult and obtain consent from your parents / legal guardians to submit your personal data before so doing. By submission of your personal data, you have signified that you have obtained such consent from your parents / legal guardians.
We will ensure that your personal data is processed lawfully, fairly, and transparently, without adversely affecting your rights. We will only process your personal data if at least one of the following basis applies:
- you have given consent to the processing of your personal data for one or more specific purposes;
- processing is necessary for the performance of a contract to which you are a party or in order to take steps at the request of you prior to entering into a contract;
- processing is necessary for compliance with a legal obligation to which we are subject;
- processing is necessary to protect the vital interests of you or of another natural person;
- processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller; and/or
- processing is necessary for the purposes of the legitimate interests pursued by us or by a third party, except where such interests are overridden by the fundamental rights and freedoms of the data subject which require protection of personal data, in particular where the data subject is a child
Purpose of collection
We (and third party data processors acting on our behalf) may collect, store and process your personal data:
- to reply to the enquiries raised by you;
- to make this Website available to you and to provide you with content which is tailored to your individual tastes or needs;
- with your consent, to contact you about beNovelty offers and sending you newsletters, marketing promotion materials in relation to beNovelty services and/or applications, and information regarding our activities, announcement, campaigns, events and survey relating to our services and applications;
- to provide our services, applications and / or beta testing of products / services to you;
- to contact you, to solicit further information and/or to provide you with the services as stipulated in and in accordance with the forms and/or other documents (in whatever format) through which you submit your personal data to us;
- to process your job application;
- for the purposes specified in the forms and/or other documents (in whatever format) through which you submit your personal data to us;
- for research, analysis, testing, monitoring, risk management and administrative purposes; and
- for any purposes directly related to the above, or where we have a legal right or duty (without any requirement of consent) to use or disclose your information (including for crime and fraud prevention and related purposes).
Unless otherwise indicated, your submission of the personal data shall be deemed as your authorization to us, our subsidiaries, associated companies, service providers and / or agents for collecting, processing and using your personal data for the above mentioned purposes.
Use of personal data
Unless you indicated otherwise, the personal data provided will be used by beNovelty only.
Notwithstanding the aforesaid, we will not share your personal data to others for their use of the personal data in direct marketing (save for sharing your personal data to our service providers / agents for direct marketing on our behalf) unless a written consent is obtained from you.
beNovelty (by beNovelty Limited) will endeavour to ensure that your personal data are being protected from any unauthorized or accidental access, process or clearance. beNovelty Limited will comply with the requirements of the Personal Data (Privacy) Ordinance (Cap. 486 of the laws of Hong Kong) or the Personal Data Protection law (Law No. 8/2005) in Macau in processing your personal data.
If you do not wish to receive further promotional offers, newsletter or news from us, please write to us at email@example.com.
Storage of personal data
We only keep your data for as long as We need to in order to use it as described above in Purpose of collection, and/or for as long as We have your permission to keep it. In any event, We will conduct an annual review to ascertain whether we need to keep your data. Your data will be deleted if we no longer need it.
Data security is of great importance to Us, and to protect your data We have put in place suitable physical, electronic and managerial procedures to safeguard and secure data collected through Our Site.
Steps We take to secure and protect your data include:
- Roles and Permissions to access data
- Masking Sensitive Data - Encryption and Pseudonymization
- Audit Trail of Database Activity
- Alerts to notify unauthorized breach attempt
- Alerts and preventive measures on accidental loss of data
- Scanning for data duplications
Notwithstanding the security measures that We take, it is important to remember that the transmission of data via the internet may not be completely secure and that you are advised to take suitable precautions when transmitting to Us data via the internet.
What Happens if Our Business Changes Hands?
In the event that any of your data is to be transferred in such a manner, you will be contacted in advance and informed of the changes.
Third party sites
Your right to withdraw or withhold Information
You may access Our Site without providing any data at all. However, to use all features and functions available on Our Site or product and/or service We provide you may be required to submit or allow for the collection of certain data.
You may withdraw your consent for Us to use your personal data as set out in What Data do We Collect? at any time by contacting Us using the details set out in Contacting Us, and We will delete Your data from Our systems. However, you acknowledge this may limit Our ability to provide the best possible products and/or services to you.
Access to Information
You have the right to request access to and correct your personal data retained by the us. You may make written request to us at firstname.lastname@example.org We reserve the rights to charge you reasonable administrative costs.
Summary of Your Rights
Under the law, you have:
- the right to request access to, deletion of or correction of, your personal data held by Us;
- the right to complain to a supervisory authority;
- be informed of what data processing is taking place;
- the right to restrict processing;
- the right to data portability;
- object to processing of your personal data;
- rights with respect to automated decision-making and profiling
Please ensure that your query is clear, particularly if it is a request for information about the data We hold about you (as under Access to Information, above).
Updates to this policy