STATEMENT OF POLICY
The protection of privacy in relation to personal data is the concern of every person in GREIFENBERG CAPITAL COMPANY LIMITED. (referred to hereinafter as the “Company”). The Company respects personal data privacy and is committed to fully implementing and complying with the requirements under the Personal Data (Privacy) Ordinance (Cap. 486) (“PDPO”). Personal data will be collected only for lawful and relevant purposes and all practicable steps will be taken to ensure that personal data held by the Company is accurate. The Company will take all practicable steps to ensure security of the personal data and to avoid unauthorized or accidental access, erasure or other use.
STATEMENT OF PRACTICES
INFORMATION COLLECTED WHEN YOU VISIT OUR WEBSITES
When you browse this website, cookies will be stored in your computer’s hard drive. The purpose of using cookies is to facilitate the content display and successful redirection to the correct page upon your clicking on the changing banner. We do not collect or store any personal data from you under this circumstance. You have a choice not to accept the cookies, but if you do, certain functionality, i.e. banner redirection and certain content display may not be available.
STATISTICS ON VISITORS TO OUR WEBSITE
When you use this website, the Company will record your visit only as a “hit” and do not collect any information which identifies your personal identity until you in fact decide to buy any of our products. Our service providers make a record of your visit that includes but not limited to IP addresses (and domain names), the types and configurations of browsers, language settings, geo-locations, operating systems, previous sites visited, and time/duration and the pages visited.
LINKS TO THIRD PARTY
This website may contain links to third party websites. The Company does not provide your personal data to these third party websites. However, the Company has no control over these third party websites. You should review the privacy policies applicable to these third party websites to understand the ways in which these third parties may collect and deal with your personal information.
The Company ensures personal data is not kept longer than is necessary for the fulfillment of the purpose for which the data is or is to be used.
The Company applies strict measures to safeguard the confidentiality of personal data. We limit access to your personal data to people working for us on a business need to know basis who shall ensure that your personal data are protected against unauthorized or accidental access, processing, erasure, loss or use.
We store information under a secure site with 128-bit encryption. Personal data to and from the Company is encrypted through the Secure Socket Layer (SSL) protocol.
COLLECTION OF PERSONAL DATA
From time to time it is necessary for the Company to collect your personal data which may be used, stored, processed, transferred, disclosed or shared by us for purposes (“Purposes”), including:
- offering, providing and marketing to you the products/services of the Company or other companies of GREIFENBERG CAPITAL COMPANY LIMITED. or our business partners (see “Use and provision of personal data in direct marketing” below), and administering, maintaining, managing and operating such products/services;
- processing and evaluating any applications or requests made by you for products/services offered by the Company and our affiliates;
- providing subsequent services to you, including but not limited to administering the policies issued;
- any purposes in connection with any claims made by or against or otherwise involving you in respect of any products/services provided by the Company and/or our affiliates, including investigation of claims;
- evaluating your financial needs;
- designing products/services for customers;
- conducting market research for statistical or other purposes;
- matching any data held which relates to you from time to time for any of the purposes listed herein;
- making disclosure as required by any applicable law, rules, regulations, codes of practice or guidelines or to assist in law enforcement purposes, investigations by police or other government or regulatory authorities in Hong Kong or elsewhere;
- conducting identity and/or credit checks and/or debt collection;
- complying with the laws of any applicable jurisdiction;
- carrying out other services in connection with the operation of the Company’s business; and
- other purposes directly relating to any of the above.
Please note that if you do not provide us with your personal data, we may not be able to provide the information, products or services you need or process your request.
TRANSFER OF PERSONAL DATA
Personal data will be kept confidential but, subject to the provisions of any applicable law, may be provided to:
- any of our affiliates, any person associated with the Company, any reinsurance company, claims investigation company, your broker, industry association or federation, fund management company or financial institution in Hong Kong or elsewhere and in this regard you consent to the transfer of your data outside of Hong Kong;
- any person (including private investigators) in connection with any claims made by or against or otherwise involving you in respect of any products/services provided by the Company and/or our affiliates;
- any agent, contractor or third party who provides administrative, technology or other services (including direct marketing services) to the Company and/or our affiliates in Hong Kong or elsewhere and who has a duty of confidentiality to the same;
- credit reference agencies or, in the event of default, debt collection agencies;
- any actual or proposed assignee, transferee, participant or sub-participant of our rights or business; and
- any government department or other appropriate governmental or regulatory authority in Hong Kong or elsewhere.
For our policy on using your personal data for marketing purposes, please see the section below “Use and provision of personal data in direct marketing”.
Transfer of your personal data will only be made for one or more of the Purposes specified above.
USE AND PROVISION OF PERSONAL DATA IN DIRECT MARKETING
The Company intends to:
- use your name, contact details, products and services portfolio information, transaction pattern and behaviour, financial background and demographic data held by the Company from time to time for direct marketing;
- conduct direct marketing (including but not limited to providing reward, loyalty or privileges programmes) in relation to the following classes of products and services that the Company, our affiliates, our co-branding partners and our business partners may offer:
- insurance, banking, provident fund or scheme, financial services, securities and related products and services;
- products and services on health, wellness and medical, food and beverage, sporting activities and membership, entertainment, spa and similar relaxation activities, travel and transportation, household, apparel, education, social networking, media and high-end consumer products;
- the above products and services may be provided by the Company and/or:
- any of our affiliates;
- third party financial institutions;
- the business partners or co-branding partners of the Company and/or affiliates providing the products and services set out in 2 above;
- third party reward, loyalty or privileges programme providers supporting the Company or any of the above listed entities;
- in addition to marketing the above products and services, the Company also intends to provide the data described in 1 above to all or any of the persons described in 3 above for use by them in marketing those products and services, and the Company requires your written consent (which includes an indication of no objection) for that purpose
Before using your personal data for the purposes and providing to the transferees set out above, the Company must obtain your written consent, and only after having obtained such written consent, may use and provide your personal data for any promotional or marketing purpose.
You may in future withdraw your consent to the use and provision of your personal data for direct marketing.
If you wish to withdraw your consent, please inform us in writing to the address in the section on “Data Access and Correction”. The Company shall, without charge to you, ensure that you are not included in future direct marketing activities.
DATA ACCESS AND CORRECTION
Under the PDPO, you have the right to ascertain whether the Company holds your personal data, to obtain a copy of the data, and to correct any data that is inaccurate. You may also request the Company to inform you of the type of personal data held by it.
Requests for access and correction or for information regarding policies and practices and kinds of data held by the Company should be addressed in writing to:
Data Privacy Officer
- GREIFENBERG CAPITAL COMPANY LIMITED.
Address: – Suite 801, Siu On Center, 188 Lockhart Road, Wanchai, Hong Kong
A reasonable fee may be charged to offset the Company’s administrative and actual costs incurred in complying with your data access requests.