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隱私政策

Personal Data (Privacy) Policy Statement (“Privacy Policy”)

DATE UPDATED: 16/5/2018 VER1.1

 

Starlane Global Limited. and/or its subsidiary(ies) and/or affiliates (hereinafter collectively referred to as the “Company”; if the context requires or permits, “Company” may refer to any one of Starlane Global Limited. and/or its subsidiary(ies) and/or affiliate(s)) pledges to meet fully with the requirements of the Personal Data (Privacy) Ordinance, Chapter 486 of the Laws of Hong Kong. In doing so, the Company will ensure compliance by its staff to the strictest standards of security and confidentiality in respect of all personal information and data submitted by users via lovsay.com, its sub-domains, any other websites, media platforms or applications including Starlane Global mobile applications and mobile webs operated/developed by the Company (hereinafter singly or collectively referred to as the “Channels” ) and the Company will not release such information to anyone without the prior consent of the relevant user(s) of the Channels (whether registered or not) (“User(s)”) except to the authorized persons listed under Section 3 below titled “Disclosure or Transfer of Data”.

Users are strongly recommended to read this Privacy Policy carefully to have an understanding of the Company’s policy and practices with regard to the treatment of personal information and data provided by the Users on the Channels. This Privacy Policy is applicable to both registered and non-registered Users, and the provisions herein may be updated, revised, varied and/or amended from time to time as the Company deems necessary.

If Users have questions or concerns regarding this Privacy Policy, they should first contact the Company, whose contact details are set out under Section 12 entitled “Enquiries” below.

 

  1. Purpose of Collection of Personal Data

1.1 In the course of using the Channels, Users may disclose or be asked to provide personal information and/or data. In order to have the benefit of and enjoy various services offered by the Channels, it may be necessary for Users to provide the Company with their personal information and/or data. Although Users are not obliged to provide the information and/or data as requested on the Channels, the Company will not be able to render certain services on the Channels in the event that Users fail to do so.

1.2 The Company’s purposes for collection of information and data on the Channels include but not limited to the following:

  1. for the daily operation of the services provided to Users;
  2. to identify Users who have posted advertisements, materials, messages, photos, views or comments or such other information (collectively “Information”) on the Channels;
  3. to identify Users who have viewed the Information posted on the Channels;
  4. to provide Users with the services of the Company;
  5. to verify the identity of Users who have used services provided by the Channels;
  6. to handle and follow up service calls, enquiries, requests and complaints;
  7. to provide Users with marketing information and promotional materials;
  8. to identify Users who have enjoyed their benefits as members of the Channels by receiving and using marketing and promotional materials;
  9. to provide Users with platforms and forum, sub-forums for posting photos, sharing and discussing the topics related to the threads submitted by other Users.
  10. to allow members of the Channels to enjoy their benefits as members by enrolling for special events hosted by the Company if there are any;
  11. to contact Users regarding administrative notices and communications relevant to the Users’ account maintained with the Company (if any), and/or regarding notifications and confirmation in connection with their uses of any of the services offered by the Company via the Channels;
  12. to design, develop and improve products and services provided to Users;
  13. to compile and analyze aggregate statistics about the Users’ use of the Channels and service usage by the Users for the Company’s internal use;
  14. to facilitate the Company to use the Users’ personal data for purposes relating to the provision of services offered by the Company and marketing services, special events and/or promotions of the Company and/or its clients;
  15. to enforce the Terms and Conditions and other rights of the Company;
  16. to comply with legal obligations and as otherwise agreed by Users as required or permitted by applicable law;

for any other purposes relating to the purposes stated above.

1.3 The User agrees that he or she is above the age of 18 when using the services of this website or any other Channels offered by the Company. We are not to be held liable or responsible for any content shown to the User and as such, persons under the age of 18 are not recommended to use the Channels and yet if they proceed, they are at their own risk of doing so.

1.4 The Company strives to only collect personal data which is necessary and adequate but not excessive in relation to the purposes set out hereinabove. 

1.5 All the data Starlane Global collects on the use of any of the Channels is the property of Starlane Global, its subsidiaries, and affiliates.

1.6 If the Company requires the use of Users’ personal data for a purpose other than those set out hereinabove, the Company may request the Users’ prescribed consent to the same.

 

  1. Collection of Personal Data

2.1 The Company may collect personal information and/or data about a User such as his/her name, log-in ID and password, address, email address, phone number, age, sex, date of birth, country of residence, nationality, education level and work experience that is/are not otherwise publicly available. Occasionally, the Company may also collect additional personal information and/or data from a User in connection with contests, surveys, special offers alike.

2.2 The Company automatically collects some information from Users’ computers or devices when Users visit the Channels. For instance, the Company will collect Users’ IP address, web browser software and referring websites. The Company may also collect information about Users’ activities conducted via the Channels, such as content viewed, pages visited, and searches and/or services used. 

2.3 When Users use the Channels on a device, the Company will additionally collect information about the Users’ location if Users have set their devices to send such information to the Channels via the privacy settings on their devices, or if Users have uploaded photos tagged with information regarding their location. The Company may use the information regarding the location collected from the Users’ devices or photos to enhance their use of the Channels by providing them with relevant content. 

2.4 Only duly authorized staff of the Company will be permitted to access the Users’ personal information and data, and the Company shall not release such personal information and data to any third parties save and except for the circumstances listed out under the Section 3 entitled “Disclosure or Transfer of Data” below. However, the Company cannot guarantee that entitles beyond authorized staff cannot access the data if due to a breach or hacking event.

 

  1. Disclosure or Transfer of Data

3.1 The Company agrees to take all practicable steps to keep all personal information and data of Users confidential and/or undisclosed, subject to the following. 

3.2 Generally speaking, the Company will only disclose and/or transfer Users’ personal information and/or data to the Company’s personnel and staff for the purposes as set out in Section titled “Purpose of Collection of Personal Data” above. However, the Company may disclose and/or transfer such information and/or data to third parties under the following circumstances:

  1. where the information and/or data is disclosed and/or transferred to any agents or associates of the Company who have been duly authorized by the Company to use such information and/or data;
  2. where permitted under the “Terms and Conditions”;
  3. where the Company needs to protect and defend its rights and property;
  4. where the Company considers necessary to do so in order to comply with the applicable laws and regulations, including without limitation compliance with a judicial proceeding, court order, or legal process served on the Channels; and
  5. where the Company deems necessary in order to deliver the services that the Company offer and to maintain and improve the services on the Channels.
  6. where the Company may disclose or transfer Users’ information to a third party if the Company sells, transfers, divests, or discloses all or a portion of its business or assets to another company in connection with or during negotiation of any merger, financing, acquisition, bankruptcy, dissolution, transaction, or proceeding. Such third party will have to comply with the appropriate confidentiality and security measures.

3.3 Personal data collected via the Channels may be transferred, stored and processed in any country in which the Company operate. By using the Channels, Users are deemed to have agreed to, consented to and authorized the Company to disclose and/or transfer their personal information and data under the circumstances stated above, as well as to any transfer of information (including the Information) outside of the Users’ country.

 

  1. Cookies and Log Files

4.1 The Company does not collect any personally identifiable information from any Users whilst they visit and browse the Channels, save and except where such information of the Users is expressly requested. When Users access the Channels, the Company records their visits only and do not collect their personal information or data. The Channels’ server software will also record the domain name server address and track the pages the Users visit and store such information in “cookies”, and gather and store information like internet protocol (IP) addresses, browser type, referring/exit pages, operating system, date/time stamp, and clickstream data in log files. All these are done without the Users being aware that they are occurring. 

4.2 The Company, third-party vendors and service providers engaged by the Company use the Company’s cookies and third-party cookies, such as the Google Analytics and Mixpanel cookies, together to inform, optimize, and serve marketing materials based on the Users’ past visits to or uses of the Channels.

4.3 The Company does not link the information and data automatically collected in the above manner to any personally identifiable information. The Company generally uses such automatically collected information and data to estimate the audience size of the Channels, gauge the popularity of various parts of the Channels, track Users’ movements and number of entries in the Company’s promotional activities and special events, measure Users’ traffic patterns and administer the Channels. Such automatically collected information and data will not be disclosed save and except in accordance with the Section 3 entitled “Disclosure or Transfer of Data”.

 

  1. Analytics Tools

5.1 Google Analytics Advertising Features (“Features”) are implemented on the Channels. The Features which the Company has implemented are based on Google Analytics Demographics and Interest Reporting. 

5.2 Google Analytics is a web analysis service provided by Google which utilizes the data collected to track and examine the use of the Channels, to prepare reports on the Users’ activities and share them with other Google services. Google may use the data collected to contextualize and personalize the marketing materials of its own advertising network. The Company also uses other data and web traffic analytics tools provided by third parties such as Mixpanel or others to collect and report on data collected from Users.

For details on how Google uses data when Users use the Channels, please visit https://www.google.com/policies/privacy/partners. Users can opt out of Google Analytics here .

 

  1. Links to Other Websites / Media Platforms / Applications

6.1 The Channels may provide third party links to other websites / media platforms / applications which are not owned or controlled by the Company. Personal information and data from Users may be collected on these other websites / media platforms / applications when Users visit such websites / media platforms / applications and make use of the services provided therein. Where and when Users decide to click on any advertisement or hyperlink on the Channels which grants Users access to another website / media platforms / applications, the protection of Users’ personal information and data which are deemed to be private and confidential may be exposed in these other websites / media platforms / applications. Users are responsible themselves to review the security and reliable of any of these third party hyperlinks when accessing them. The Company is not responsible for any loss or damage caused by any third party hyperlinks to the User’s software or hardware.

6.2 Non-registered Users who gain access to the Channels via their accounts in online social networking tools (including but not limited to Facebook) are deemed to have consented to the terms of this Privacy Policy as well as the Terms & Conditions, and such Users’ personal data which they have provided to those networking tools may be obtained by the Company and be used by the Company and its authorized persons in and outside of the User’s country for the purpose of providing services and marketing materials to the Users. 

6.3 If a User logins to any Channels with his/her Facebook account, the Company will collect and store the User’s personal profile and information, such as but not limited to User’s name, registered email, profile picture, gender, friend list, age, interests which the User has chosen to make available to the Channels. All Users are deemed to have consented to the Company and its authorized personnel’s access and use of their personal data so obtained for the purposes as stipulated under Clause 1 above and/or share their personal data pursuant to Clause 3 above, subject to the other provisions of the Privacy Policy. 

6.4 This Privacy Policy is only applicable to the Channels. Users are reminded that this Privacy Policy grants no protection to Users’ personal information and data that may be exposed on websites / media platforms / applications other than the Channels, and the Company is not responsible for the privacy practices of such other websites / media platforms / applications. Users are strongly recommended to refer to the privacy policy of such other websites / media platforms / applications. For the avoidance of doubt, the Company assumes no responsibility or liability for Users’ use of such other websites / media platforms / applications.

 

  1. Security

7.1 The security of Users’ personal information and data is important to the Company. The Company will always strive to ensure that Users’ personal information and data will be protected against unauthorized access. The Company has implemented appropriate electronic and managerial measures in order to safeguard, protect and secure Users’ personal information and data. 

7.2 All personal information and data provided by Users are only accessible by the authorized personnel of the Company or its authorized third parties, and such personnel shall be instructed to observe the terms of this Privacy Policy when accessing such personal information and data. Users may rest assured that their personal information and data will only be kept for as long as is necessary to fulfill the purpose for which it is collected, unless Users request the Company to cease to hold the same or terminate his/her membership account with the Company. Such request may render the Company unable to further provide its services, information and/or promotional materials for your benefit in the future. 

7.3 Registered Users should safeguard his/her unique Username and Password by keeping it secret and confidential and never share these details with anyone. 

7.4 The Company follows generally accepted industry standards such as SSL to protect the personal information and data submitted by Users to the Channels, both during transmission and once the Company receives it. However, no method of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, while the Company strives to protect Users’ personal information and data against unauthorized access, the Company cannot guarantee its absolute security and is not liable to any losses caused by any loss of data.

 

  1. Access to or request for correction of data

8.1 The Company would like to help Users keep his/her personal information accurate and up-to-date. To view or edit personal information that has been stored at the Channels, please visit the your User Account section. 

8.2 Any User may make a data access request or a data correction request at any time by contacting the Company using email.

8.3 In the event that a User wishes to access or amend his/her personal information and data, the Company may request him/her to provide personal details in order to verify and confirm his/her identity. HKID card number or passport number or business registration certificate number cannot be amended unless such data is proved to be inaccurate. The Company will respond to Users’ request within 60 days of his/her request. 

8.4 If Users do make a data access request and if the Company deems the same as appropriate, only a copy of his/her personal data would be provided.

 

  1. Retention of Personal Data

Once the Company has obtained a User’s personal information and/or data, it will be maintained securely in the Company’s system. Subject to legal requirements, the personal information and/or data of Users will be retained by the Company until the User requests the Company in writing to erase his/her own personal information and/or data from the Company’s database or to terminate his/her membership of the Channels.

 

  1. Changes in this Privacy Policy

10.1 The Company reserves the right to update, revise, modify or amend this Privacy Policy in the following manner at any time as the Company deems necessary and Users are strongly recommended to review this Privacy Policy frequently. If the Company decides to update, revise, modify or amend this Privacy Policy, the Company will post those changes to this webpage and/or other places the Company deems appropriate so that Users would be aware of what information the Company collects, how the Company uses it, and under what circumstances, if any, the Company discloses it. 

10.2 If the Company makes material changes to this Privacy Policy, the Company will strive to notify all Users timely on this webpage and/or other digital means deemed necessary by the Company but the Company cannot guarantee that all of its Users shall receive all the notifications in time.

 

  1. Inconsistency

Should there be any inconsistency between the English version and any version in other languages, the English version shall always prevail.

 

  1. Enquiries

Users may inquire about their personal information and data by emailing team@www.lovsay.com