1. Your Privacy

K. Wah Group and each of its individual members and their respective subsidiaries, associated and/or related companies (collectively, the “Group” or “we”) respect your legal rights of privacy when collecting, storing, using and transmitting personal data. This Privacy Policy (the “Policy”) explains our privacy practices. It is our policy to comply with the requirements of the Personal Data (Privacy) Ordinance (Cap. 486) (the “Ordinance”) of the Laws of the Hong Kong Special Administrative Region of the People’s Republic of China (“Hong Kong”).

Please read the following carefully to understand our policy and practices regarding how your personal data will be treated. This Policy applies to users of our official website (http://www.kwah.com/) (i.e. the “Website”). If you are visiting the individual websites of any individual members of the Group and their respective subsidiaries, associated and/or related companies, kindly read and understand the individual privacy policy (if any) specifically applicable to such member and its subsidiaries, associated and/or related companies.

If there is any inconsistency between the English and Chinese version of this Policy, the English version shall prevail.

Throughout this Policy, the meaning of the term “personal data” is defined in the Ordinance.

2. Data Collection and Use

We may collect your personal data including but not limited to your name, telephone number, address and email address in order to provide you the various services and features. You are not obliged to supply the data, but if you do not, the services and features may not be available.
The purposes for which we may use your personal data are as follows:-

1. following up on comments, inquiries and complaints that users submit to the Website;
2. following up and processing your applications, registrations or subscriptions;
3. monitoring use of the Website to help their further development;
4. understanding users' needs so as to provide better services;
5. compiling aggregate statistics about users to analyze usage of the Website;
6. operating internal control, resolving disputes, troubleshooting problems and enforcing terms of use;
7. contacting users regarding administrative notices and communication;
8. collecting data for identity verification and record and maintaining contact lists for correspondence;
9. designing, providing and marketing to users facilities, services and/or products of K. Wah Group;
10. promoting, improving and/or further the provision facilities, services and/or products of K. Wah Group;
11. delivering information that users may have interest in, such as new services and products and other promotions and marketing materials;
12. recruitment and other human resources related purposes;
13. communicating with investors and/or potential investors of K. Wah Group and/or any of its subsidiaries, associated and/or related companies;
14. complying with any law binding on us or for the purposes of any guidelines or codes of practice issued by regulatory or other authorities with which we are reasonably expected to comply; and
15. any other purpose(s) which has been agreed by or notified to you.

If you are under the age of 18, you must ask your parent or guardian before providing any personal data to us.
When you visit the Website, cookies will be stored in your computer, mobile phone or other devices. The purpose of using cookies is for internal navigation/ programming, estimating our audience size, assisting us in tracking visits and measuring visitors' traffic patterns. We will not collect any personal data from you under this circumstance. You have a choice not to accept the cookies, but if you do, certain functionality may not be available.

3. Direct Marketing

We cannot use your personal data for direct marketing purposes without your consent. By providing your personal data, you are deemed to have given consent to the use of your personal data as set out in this Policy including for direct marketing. You may withdraw your consent any time by writing to the Personal Data Privacy Officer of K. Wah Group.

4. Disclosure

We will take all practicable steps to keep your personal data confidential but for any one or more purpose(s) named in paragraph 2 above, we may transfer/assign your personal data to or exchange such data with any of the following parties irrespective of whether such parties are located inside or outside Hong Kong:

1. any agent, contractor or third party service provider who provides administrative, telecommunications, computer and other services to us with respect to the operation of our business;
2. any subsidiaries, associated and/or related companies of each individual member of K. Wah Group; or
3. any person to whom we are under an obligation to make disclosure under the requirement of any law binding on us or for the purposes of any guidelines or codes of practice issued by regulatory or other authorities with which we are reasonably expected to comply.

Unless expressly stated in this Policy or with prior consent, personal data collected from you will not be disclosed to any third party other than the above-named parties.

5. Links to Other Websites

This Policy only applies to the Website. If you click on any advertisement or hyperlink linking to other website(s), you will leave the Website for another location. At any other website, the protection of your privacy, personal data and your exposure to cookies are not our responsibility and you are advised to refer to the privacy policy of that other location (if any).

6. Web Logs

When a user visits the home page of the Website, the visit will be counted and included in the total number of visits to the Website for statistical purpose. This information does not identify you as an individual. No personal data will be collected.

7. Security

Except as mentioned in paragraph 4 above, your personal data, however stored, will be accessed only by our employees or contractors who are authorized to do and under a duty of confidentiality to us. Such authorized personnel or contractors designated to handle personal data will be instructed to do so only in accordance with this Policy.

8. Use of Personal Data in Legal Proceedings

If it becomes necessary that we have to take action against you for any reason whatsoever including but not limited to recovering from you any money you owe us, you expressly agree that the personal data provided by you can be relied upon in identifying and take legal action against you.

9. Your Right to Access and Retention

You may at any time request access to and correct personal data relating to you in any of our records. To exercise any of your rights, contact us at the address below marking your communication “Confidential”. In response, we may ask you to provide certain details about yourself so that we can be sure you are the person to whom the data refers. We are required to respond to your requests within 40 days and we will endeavor to do so wherever possible, but we may charge you a reasonable fee for doing so.

10. Personal Data Privacy Officer

The person to whom (1) requests can be made (a) for accessing to data or correction of data; (b) for general information regarding our policies and practices with respect to personal data; and (c) for information about the kinds of personal data that we hold and (2) general questions and complaints should be addressed is as follows:-

Personal Data Privacy Officer
Corporate Affairs Department(Marked Confidential)
Address: 29/F, K. Wah Centre, 191 Java Road, North Point, Hong Kong

11. Retention of Data

We will only keep your personal data for as long as necessary to fulfill the purpose for which the data was collected unless the personal data is also retained to satisfy any applicable statutory or contractual obligations. Personal data which no longer required will be destroyed.