Global Privacy and Cookies

The purpose of this policy is to describe how re:look consulting limited, a company with registered office at One Capital Place, 18 Luard Road, Wan Chai, Hong Kong, collects, stores, uses and shares your data, in order to provide you with the best possible service.

We may update this policy from time to time by publishing a new version on our website. You should check this page occasionally to ensure you understand any changes to this policy.

The privacy of our website visitors is very important to us, and we are committed to safeguarding it. Consenting to our use of cookies in accordance with the terms of this policy when you first visit our website permits us to use cookies every time you visit our website

1. The type of data that we collect

For the purpose described in this policy, the following types of personal information may be collected, stored, and used:

  1. information about your computer including your IP address, geographical location, browser type and version, and operating system;
  2. information about your visits to and use of this website including the referral source, length of visit, page views, and website navigation paths;
  3. information, such as your email address, that you enter when you register with our website;
  4. information that you enter when you create a profile on our website—for example, your name, profile pictures, gender, birthday, relationship status, interests and hobbies, educational details, and employment details;
  5. information, such as your name and email address, that you enter in order to set up subscriptions to our emails and/or newsletters;
  6. information that you enter while using the services on our website;
  7. information that is generated while using our website, including when, how often, and under what circumstances you use it;
  8. information relating to anything you purchase, services you use, or transactions you make through our website, which includes your name, address, telephone number, email address, and credit card details;
  9. information that you post to our website with the intention of publishing it on the internet, which includes your username, profile pictures, and the content of your posts;
  10. information contained in any communications that you send to us by email or through our website, including its communication content and metadata; and
  11. any other personal information that you send to us.

Your personal information is collected either directly from you (e.g. when you submit an enquiry via our website) or from you passively (e.g. when using tracking tools like browser cookies), or from third parties (e.g. through social media platforms).

Before you disclose to us the personal information of another person, you must obtain that person’s consent to both the disclosure and the processing of that personal information in accordance with this policy.

You do not have to provide us with any personal data, however, if you choose not to provide your data when requested to perform a contract or when required by law, you may be unable to receive the product or service you require or otherwise registered on our website or other media.

2. Using your personal information

Personal information submitted to us through our website or social media channels will be used for the purposes specified in this policy or on the relevant pages of the website. We may use your personal information for the following:

  1. administering our website and business;
  2. personalizing our website for you;
  3. enabling your use of the services available on our website;
  4. sending you goods purchased through our website;
  5. supplying services purchased through our website;
  6. sending statements, invoices, and payment reminders to you, and collecting payments from you;
  7. sending you non-marketing commercial communications;
  8. sending you email notifications that you have specifically requested;
  9. sending you our email newsletter, if you have requested it (you can inform us at any time if you no longer require the newsletter);
  10. sending you marketing communications relating to our business or the businesses of carefully-selected third parties which we think may be of interest to you, by post or, where you have specifically agreed to this, by email or similar technology (you can inform us at any time if you no longer require marketing communications);
  11. providing third parties with statistical information about our users (but those third parties will not be able to identify any individual user from that information);
  12. dealing with inquiries and complaints made by or about you relating to our website;
  13. keeping our website secure and prevent fraud;
  14. verifying compliance with the terms and conditions governing the use of our website (including monitoring private messages sent through our website private messaging service); and
  15. other uses: we use information to maintain transaction and other business records for legal, administrative and audit purposes.

If you submit personal information for publication on our website, we will publish and otherwise use that information in accordance with the license you grant to us.

Your privacy settings can be used to limit the publication of your information on our website and can be adjusted using privacy controls on the website.

We will not, without your express consent, supply your personal information to any third party for their or any other third party’s direct marketing.

3. Disclosing your personal information

We may disclose your personal information to any of our employees, officers, insurers, professional advisers, agents, suppliers, or subcontractors as reasonably necessary for the purposes set out in this policy.

We may disclose your personal information to any member of our group of companies (this means our subsidiaries, our ultimate holding company and all its subsidiaries) as reasonably necessary for the purposes set out in this policy.

We may disclose your personal information:

  1. to the extent that we are required to do so by law;
  2. in connection with any ongoing or prospective legal proceedings;
  3. in order to establish, exercise, or defend our legal rights (including providing information to others for the purposes of fraud prevention and reducing credit risk);
  4. to the purchaser (or prospective purchaser) of any business or asset that we are (or are contemplating) selling; and
  5. to any person who we reasonably believe may apply to a court or other competent authority for disclosure of that personal information where, in our reasonable opinion, such court or authority would be reasonably likely to order disclosure of that personal information.

Except as provided in this policy, we will not provide your personal information to third parties.

4. International data transfers

  1. Information that we collect may be stored, processed in, and transferred between any of the countries in which we operate in order to enable us to use the information in accordance with this policy.
  2. Information that we collect may be transferred to the following countries which do not have data protection laws equivalent to those in force in the European Economic Area: The United States of America, Russia, Japan, China, and India.
  3. Personal information that you publish on our website or submit for publication on our website may be available, via the internet, around the world. We cannot prevent the use or misuse of such information by others.
  4. You expressly agree to the transfers of personal information described in this Section 4.

5. Tracking tools and use of Cookies

We will collect certain information through cookies and other automated means.

A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server. Cookies may be either “persistent” cookies or “session” cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed. Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies. We use both session and persistent cookies on our website.

The names of the cookies that we use on our website, and the purposes for which they are used, are set out below:

  1. we use Google Analytics and Adwords on our website to recognize a computer when a user visits the website / track users as they navigate the website / enable the use of a shopping cart on the website / improve the website’s usability / analyze the use of the website / administer the website / prevent fraud and improve the security of the website / personalize the website for each user / target advertisements which may be of particular interest to specific users;
  2. we may include in our website the possibility the share content with third parties or to let other persons know you browsed our website. Such is the “like” and “share” functionalities offered by the social media platforms;
  3. we do not control how these platforms collect your personal data while you are browsing our website. We invite you to read the Privacy policies of these social media networks for an understanding of how they use the information they collect;
  4. except for functional or security cookies, the use of cookie on a Device depends on the user’s choice which can be modified freely at any time;
  5. most browsers allow you to refuse to accept cookies—for example:
    • in Internet Explorer (version 10) you can block cookies using the cookie handling override settings available by clicking “Tools,” “Internet Options,” “Privacy,” and then “Advanced”;
    • in Firefox (version 24) you can block all cookies by clicking “Tools,” “Options,” “Privacy,” selecting “Use custom settings for history” from the drop-down menu, and unticking “Accept cookies from sites”; and
    • in Chrome (version 29), you can block all cookies by accessing the “Customize and control” menu, and clicking “Settings,” “Show advanced settings,” and “Content settings,” and then selecting “Block sites from setting any data” under the “Cookies” heading.
  6. blocking all cookies will have a negative impact upon the usability of many websites. If you block cookies, you will not be able to use all the features on our website; and
  7. you can delete cookies already stored on your computer. Deleting cookies will have a negative impact on the usability of many websites.

6. Retaining personal information

  1. Your personal information will not be kept in a form that allows you to be identified for any longer than is reasonably considered by re:look consulting for achieving the purposes for which it was collected or established in the applicable laws related to data retention periods.
  2. Without prejudice to article 6.a, data collected for the purposes defined in article 2 will be stored only:
    • for 3 years since our last contact, if you are a prospect (e.g. you enquired, however you did not make any purchase with us yet); and
    • for the duration of the contract and 7 years thereafter if you are a client (e.g. you purchase goods or services).
  3. Notwithstanding the other provisions of this Section 5, we will retain documents (including electronic documents) containing personal data:
    • to the extent that we are required to do so by law;
    • if we believe that the documents may be relevant to any ongoing or prospective legal proceedings; and
    • in order to establish, exercise, or defend our legal rights (including providing information to others for the purposes of fraud prevention and reducing credit risk).

Your personal data are then anonymized or deleted.

7. Protecting your personal information

  1. We will take reasonable technical and organizational precautions to prevent the loss, misuse, or alteration of your personal information.
  2. We will store all the personal information you provide on our secure (password- and firewall-protected) servers.
  3. All electronic financial transactions entered into through our website will be protected by encryption technology.
  4. You acknowledge that the transmission of information over the internet is inherently insecure, and we cannot guarantee the security of data sent over the internet.
  5. You are responsible for keeping the password you use for accessing our website confidential; we will not ask you for your password (except when you log in to our website).

8. Your rights

You may instruct us to provide you with any personal information we hold about you and provision of such information will be subject to the supply of appropriate evidence of your identity. For this purpose, we will usually accept a photocopy of your passport certified by a notary plus an original copy of a utility bill showing your current address.

You may instruct us at any time not to process your personal information for marketing purposes. In practice, you will usually either expressly agree in advance to our use of your personal information for marketing purposes, or we will provide you with an opportunity to opt out of the use of your personal information for marketing purposes.

You may request de deletion of your Personal Information, if your information is no longer necessary for the purpose of the data processing.

You also have the right to lodge a complaint with the competent supervisory authority.

To exercise these rights, please contact us at [email protected].

9. Third party websites

Our website includes hyperlinks to, and details of, third party websites. We have no control over, and are not responsible for, the privacy policies and practices of third parties.

Updated 5th April 2021