Personal Data (Privacy) Policy
It is the policy of Perfect Group International Holdings Limited (the “Company”) for the Company and its subsidiaries (collectively the “Group”) to comply with the Personal Data (Privacy) Ordinance (the “Ordinance”) (Chapter 486 of the Laws of Hong Kong). The Group is dedicated to respecting your privacy and implementing stringent security measures to ensure the confidentiality of your personal data.

This Policy explains our general principles in respect of the collection and handling of the personal data that you provide to us. Your personal data may be collected by us, through online, written or verbal form, under the following circumstances:-

1.when you make an enquiry to us;
2.when you make a request to us;
3.when you conduct communications or interaction with us;
4.when you apply or register for our membership or user account or participate in our events and/or activities;
5.when you purchase or subscribe for products and/or services with us; or
6.when you apply for employment with us.

You will be informed by the applicable Personal Information Collection Statement (“PICS”) of such purposes and uses of your personal data, including the extent of transfer and disclosure; and the right of access to and correction of the collected personal data. This Policy should be read together with the applicable PICS. If there is any inconsistency in the practices related to the personal data between this Policy and the PICS, the PICS should prevail.

Collection and Use of Personal Data
The Company may collect personal data from you, including but not limited to your name, address, telephone number, email address, etc. for the purposes and use specified in the PICS provided to you on or before the collection of such personal data. The provision of personal data by you is voluntary. However, if you do not provide us with the personal data requested, the Company may not be able to provide you with the information, services or activities you request in full, and the Company may not be able to fulfil your requests or respond to your enquiries.

Where you provide personal data of another individual to us, you should have obtained consent from such individual for your provision and our collection and use of his/her personal data for the purposes and use specified in the PICS.  Your provision is deemed to have obtained such individual’s consent for our collection and use of his/her personal data.

When disclosing personal data to us, you should ensure that the data you provide is complete and accurate. If you would like to change your personal data, please notify us immediately of the relevant changes so that the Company can update our records accordingly.

Use of Cookies
In order for us to provide you with personalised services, the Company uses cookies to store and track your information after you have visited or logged-in to our website(s). The information collected by means of cookies may include but not be limited to your login name, navigation pattern, IP address, domain server, type of computer and type of web browser you are using.  The Company will not collect any personal data from you when the cookies are being used.

Generally, the Company may use cookies to estimate our audience size, track your progress and number of entries in our promotional activities, assist us in tracking visits, measure your traffic patterns, customise website content specific to your interests, ensure that you do not see the same advertisement repeatedly, store your password so you do not have to re-enter it each time you use the sites, and improve and update the website(s).

At any time, you can choose whether to accept or reject cookies, your browser on your computer is often initially set to accept cookies.  However, you can choose to reject cookies and continue browsing the sites.

Disclosure and Transfer of Personal Data
The personal data collected by us will not be disclosed, provided or transferred out of the Group to any other party in a form that would identify you except to the parties as set out in the PICS provided to you on or before the collection of your personal data.  Your personal data collected by us will not be sold to any parties.

The Company may provide your personal data to the service providers providing services to the Group in connection with the specific purposes set out in the PICS.  In these cases, our service providers may use your personal data consistent with their services contracted with us as well as the PICS and the Ordinance.

In cases when the Company has reason to believe that disclosing your personal data is necessary to identify, contact or bring legal action to protect or defend our rights or against someone who may be violating the terms or may be causing injury to or interference with our rights or property, other users, or anyone else that could be harmed by such activities, the Company may disclose your personal data.  The Company may also disclose to the related parties or organisations or access your personal data when the Company believes in good faith that the law requires it.

Retention of Personal Data
The Company will take all practicable steps to ensure that your personal data is not kept longer than necessary for the fulfilment of the purpose (including any purpose directly relating or incidental to the purposes set out in the PICS provided to you on or before the collection of such personal data) for which the data is or is to be used.  Personal data that is no longer required will be destroyed.

Security of Personal Data
The Company will take practicable measures to safeguard data security including protection against unauthorised or accidental access, processing, erasure, loss or use.  Despite our effort to protect your personal data, given the nature of the internet, the Company cannot guarantee perfect security of data transmission over it.  However, once the Company receives your transmission, the Company uses our best endeavours to ensure its security in our own systems.  Your personal data will only be accessed by our authorised personnel or contractors.

Links to Other Websites
Links on the websites of the Company may link to websites maintained by third parties.  These third-party websites may have their own privacy policies and procedures which might not be bound by this Policy.  The Company makes no representation or warranty regarding the accuracy, timeliness, suitability or any other aspect of the information and content on such websites.  The protection of your personal data privacy and your exposure to cookies on such websites are not our responsibility.  Access to and use of such third-party websites is at your own risk and subject to the terms and conditions applicable to such websites.

If you interact with the Company on any social media platforms, the Company can interact with you according to the rules of the social media platforms, for example, sending messages to you via the platforms.  The Company is not responsible for how the social media operators collect, handle or use your personal information or what third parties post on our social media platforms.

Direct Marketing
The Company may not use or transfer your personal data for direct marketing purposes unless the Company has received your consent (or your indication of no objection).  Subject to your consent, the Company may use or transfer your personal data for marketing and promotion of any products, services and subjects provided by the Company or which the Company considers you may have interest in accordance with the PICS provided to you on or before the collection of your personal data.

You may communicate your consent to the use and transfer of your personal data for direct marketing purposes to us without charge at the time when you are provided with the PICS.  You may also email or write to our Data Protection Officer via the channels set out in the section “Enquiries” below to inform him of such consent.

Should you wish to cease to receive direct marketing materials and/or communications from us, you may exercise your opt-out right by email or writing to our Data Protection Officer via the channels as set out in the section “Enquiries” below.

Access to and Correction of Personal Data
You have the right to request access to, and correction of, your personal data held by us.  If you wish to check whether the Company holds your personal data, access to the personal data held by us or correct any information relating to you which is inaccurate, please email or write to our Data Protection Officer via the channels as set out in the section “Enquiries” below.

The Company may ask you to provide your identity proof or any other necessary information for the verification of your identity in order to help us respond more efficiently to your request.

A reasonable fee may be charged for the administrative costs incurred by us in relation to administering and complying with your data access request.