Privacy Policy and Personal Information Collection Statement

TOM Group Limited ("TOM") and its subsidiary companies whose place of business are located in Hong Kong ("we", "us") are committed to complying with the Personal Data (Privacy) Ordinance, Chapter 486 of the laws of the Hong Kong (the Ordinance"). Our privacy policy statement ("PPS") and personal information collection statement ("PICS") as set out herein ("Statement") explain the privacy policy and practice regarding how we use and protect any personal data that you provide.

Please read this Statement to understand our policy and practices and purposes for collection of your personal data.

TOM and its subsidiary companies may, due to the operational needs or activities organized at the time, collect your personal data when you are browsing the webpages or websites of these subsidiary companies or activities. Such information relating to your personal data may include, without limitation, your name, date of birth, gender, contact information, e-mail address, education level, occupation, interests and favourite activities. Please make sure that you also read and understand the individual PPS(s) and/or PICS(s) of our subsidiary companies or the activities to be engaged by you with us, if any, specifically applicable to such subsidiary companies and the relevant activities.

YOU HEREBY AGREE THAT THE INFORMATION YOU PROVIDE TO US IS PROVIDED VOLUNTARILY, AND IS ACCURATE, TRUE, CURRENT AND COMPLETE. If this is not the case or we have reasonable grounds to suspect as such, we have the right to cancel your registration and/or refuse any and all current or future use of our websites and its services to you. If the information you provide to us is incomplete or incorrect, we may not be able to provide or continue to provide the products and/or services offered on our websites to you or may not permit you or may discontinue your access to our websites. You understand and acknowledge that all or any part of the information you provide to us will be collected and may be used for one of more of the purposes set out in the “Purposes of collection” of this Statement.

You should read and understand our PPS(s) and PICS(s) now and again as these PPS(s) and/or PICS(s) may be revised from time to time as we deem necessary.

The PPS(s) and/or PICS(s) as mentioned only apply to us. If you click on any hyperlink linking to another website, you will leave our websites for another location. We shall not be responsible for the privacy and security practices or the content of such websites and you should always check the privacy policy of all websites you click in.

Data Collection and Use

Use of cookies

Like many other websites, we record your visit automatically through cookies, which are some small data structures sent to your computer to record your visit to our official website and to identify you during your future visits. You may refuse to accept these cookies by activating such setting on your browser. However, if you select the cookies refusal setting, you may be unable to fully experience certain features of our websites.

We may also collect information regarding your IP address, browser type, domain name and access time. This information is used for our own research purposes. As it is not linked to any personal information, it is separate from your personal data.

Purposes of collection

In some circumstances, your personal data may be requested by us (whether online or at one of our workplaces) and collected from you as user or customer on a voluntary basis, which may include your name and contact information that we believe to be necessary or relevant for any of the following purposes and for other purpose as may be agreed by or notified to you or required by law from time to time:

Providing services, goods, support, and facilities or performing administrative work and transactions related to our operations;

Processing user or customer’s request for services or activities provided by us;

Collecting data for identity ratification and records;

Analyzing and comparing your information with that of others for product and/or services customization and/or marketing (direct of otherwise) purposes;

Enabling TOM to comply with its obligations to interconnect or other industry practices;

Sending you information about different products and services;

Maintaining contact lists for correspondence;

Performing procedures for comparing user’s or customer’s data with other information supplied by the user or customer (for whatever purpose), including, without limitation, procedures undertaken for the purpose of taking adverse action against the user or customer (whether such comparison is by manual or automated means);

Forwarding publicity and/or marketing materials or other information to the users or customers from charitable organisations or any other types of organizations selected by us from time to time;

Carrying out the user’s or customer’s instructions, responding to enquiries by that user or customer or made on his/her behalf and providing user or customer with an effective and efficient service;

Responding to inquiries or expression of interest;

Contract implementation and enforcement;

Recruitment and human resource management including online job applications;

Prevention or detection of crime;

Complying with the requirements to make disclosures under the requirements of any law;

Monitoring use of website to help its further development;

Compiling statistics about our users or customers to analyze site usage or aggregated consumer behavior; and/or Implementing any other purposes relating to the above.

You are not obliged to supply the personal data. However, refusal to supply may result in us being unable to process your request. We will not purposely or intentionally use, disclose, transfer or sell your personal data in such circumstances which are unrelated to the above purposes without your prior consent.

We may from time to time send direct marketing materials for business promotion to users/customers based on their personal information. We will first obtain your consent or indication of no objection before doing so and suitable opt-out mechanisms will be provided in accordance with the Ordinance.

Security of Personal Data

We are committed to protecting the security of your personal data.

We strive to ensure compliance by our staff with the strictest standards of security and confidentiality.

We use a variety of security technologies and procedures to help protect your personal data from unauthorized access and use. As effective as modern security practices are, no physical or electronic security system is entirely secured. We cannot guarantee the complete security of our database, nor can we guarantee that data you supply will not be intercepted while being transmitted to us over the Internet or otherwise. We have implemented internal guidelines to ensure as far as possible that your privacy is safeguarded at every level of our organization.

Although we will do our best to protect your personal data, we cannot guarantee the security of your personal data transmitted to our website. Any transmission of personal data is at your own risk. Once we have received your personal data, we will use appropriate security measures to seek to prevent unauthorized access or disclosure.

Disclosure and Transfer of Personal Data

We take your privacy seriously. Unless expressly stated in this Statement, our policy is not to disclose any personal data to any third parties except with your prior consent or required by law. All personal data you provided to us are secured with restricted access by authorized personnel only.

We may disclose and transfer your personal data (whether in Hong Kong or abroad), under strict confidence, to our agents or contractors who provide administrative, data processing, market research, distribution, telecommunications, professional or other similar services to us and to any of our actual or proposed assignees or transferees of our rights with respect to you in connection with a proposed or progressing merger, sale or transfer (whether of assets or shares), to use, hold, process or retain such personal data for the purposes stated above. These third parties may have their independent policies and practices in respect of the collection, use and protection of personal data. This Statement does not cover the policies and practices of any third parties.

Data Retention

We will only retain the personal data for so long as necessary to fulfill the purposes for which it was collected and for the purposes of satisfying our legal, accounting or compliance-related requirements after which it will be destroyed without further notice to you.

To determine the appropriate retention period, we will have regard to the amount, nature, sensitivity, the potential risk of harm from unauthorized use or disclosure of the personal data, the purposes for which we collect/process the personal data and the applicable legal requirements.

Data Access and Correction

You have the right to request access to and correction of your personal data in accordance with the provisions of the Ordinance. Any data access request or data correction request may be made to our Data Protection Officer by post to TOM Group Limited, Rooms 1601-05, China Resources Building, 26 Harbour Road, Wanchai, Hong Kong and marked (Confidential).

In accordance with the Ordinance, we have the right to charge a reasonable fee for the processing of any data access request.

Contact Us

If you have any questions about our privacy policy and practices, you may contact our Data Protection Officer by post to TOM Group Limited, Rooms 1601-05, China Resources Building, 26 Harbour Road, Wanchai, Hong Kong and marked (Confidential).

English Version and Chinese Translation

This Statement has been translated into Chinese language. If there is any inconsistency or ambiguity between the English version and the Chinese version, the English version shall prevail.