Flink Communications Limited (referred to as “our company“, “we“, “us” and “our“) takes individuals’ privacy seriously. This Statement explains our policies and practices and applies to information collection and use including but not limited to while you are visiting and using flinkcomm.com (the “Site“).
We respect your privacy and we promise:
• to implement computer, physical and procedural safeguards to protect the security and confidentiality of the personal data we collect
• to limit the personal data collected to the minimum required to provide services requested by you
• to permit only our properly trained, authorized employees to access personal data
• not to disclose your personal data to external parties unless you have agreed, we are required by law or we have previously informed you.
- Information collection
In order to provide a better service to you, we may, in the course of and in relation to provision of our services or products, collect and process the following information about you:
• information (such as your name, your company name, address, telephone number, mobile phone number, fax number, email address, website, nature of business and product/service details etc. of your company) when you register with us, use our services, attend our functions, or communicate with us. In some circumstances, we may also collect personal identification data for security and verification purposes;
• in connection with an account sign-in facility, your log-in and password details;
• the content of any communications you send to us, for example, to report a problem or to submit queries, concerns or comments regarding the Site or its content; and
• information from surveys that we may, from time to time, run on the Site for research purposes, if you choose to respond to, or participate in, them.
The provision of personal data by you is necessary in order for us to provide you with the requested services and for us to perform our contractual obligations (if any) to you. You are also responsible for ensuring that the personal data provided to us are accurate and up-to-date. If you do not supply such data or do not supply data that are up-to-date, we may be unable to provide the requested service.
We only retain personal data for so long as it is necessary for the fulfillment of the purpose (including any directly related purpose) for which the data is or is to be used.
In addition, when you browse the Site, we will collect the basic technical information that your browser sends to the Site such as your browser type and language, access times, the address of the site from which you came to the Site, your Internet Protocol (IP) address, or click stream data within our website (i.e. the actions taken in connection with the Site) etc. We collect such technical information during your visit to the Site through our automatic data collection tools, which may include cookies and other commonly used technologies. We collect such data for the purpose of improving the functionality of the Site. Further information on cookies is set out below.
- Use of information
The purposes for which information may be used by us in and outside Hong Kong include:
(a) delivering information and managing event registrations
(b) providing services and information offered through the Site
(c) providing services to facilitate business between Hong Kong and overseas (or otherwise), and providing enquirers with contact and business information
(d) our operations, e.g., incorporation into our database, analysis, research and auditing
(e) notification of LKG (as defined below) events in Greater China and overseas (and similar events or trade fairs organized by our business partners and counterparts)
(f) distribution of LKG (as defined below) publications and marketing materials (and those of our business partners and counterparts)
(g) marketing LKG (as defined below) services or products (including business partners and counterparts engaged in similar or peripheral activities, such as business matching services, sourcing and conferences)
(h) complying with laws, regulations or codes of practice in or outside Hong Kong
(i) legal proceedings, including collecting overdue amounts
(j) other purposes directly relating to the activities identified above
(k) prevention or detection of crime, and protection of the security and safety of our events
(l) verification of identity in events organised by us where it is necessary to verify your identity
We may disclose your personal data to third parties for the purpose outlined at paragraph 2 above, including but not limited to the following third parties:
• Companies within the Lee Kee Group (“LKG”), a list of which may be found at [https://www.leekeegroup.com/organization-structure/] and which may be updated from time to time, for the purpose of handling and providing services to you;
• personnel, agents, advisers, auditors, contractors, financial institutions, and service providers in connection with our operations or services
• our overseas offices, affiliates, business partners and counterparts
• persons under a duty of confidentiality to us
• persons to whom we are required to make disclosure under applicable laws in or outside Hong Kong
• any law enforcement agencies, regulatory authorities, government departments and related organizations, courts and tribunals, within Hong Kong or in Mainland China.
We may provide your personal data as required or permitted by law to comply with a summons, subpoena or similar legal process or government request, or when we believe in good faith that disclosure is legally required or otherwise necessary to protect our rights and property, or the rights, property or safety of others, including but not limited to advisers, law enforcement, judicial and regulatory authorities in or outside Hong Kong. We may also transfer your personal data to a third party that acquires all or part of our assets or shares, or that succeeds us in carrying on all or a part of our business, whether by merger, acquisition, reorganization or otherwise.
Cookies are small, sometimes encrypted text files that are stored on computer hard drives by websites that you visit. They are used to help you to navigate on websites efficiently as well as to provide information to the owner of the website. Cookies do not contain any software programs. There are two general types of cookies, session cookies and persistent cookies. Session cookies are only used during a session online and will be deleted once you leave a website. Persistent cookies have a longer life and will be retained by the website and used each time you visit a website. Both session and persistent cookies can be deleted by you at anytime through your browser settings and in any event, will not be kept longer than necessary.
We may use an email delivery and marketing company to send emails that you have agreed to receive. Pixels tags and cookies are used in those emails and at our Site to help us measure the effectiveness of our advertising and how visitors use our web site.
Personal data stored electronically are password-protected. Encryption technology is used on our secured web areas. Our computer systems are placed in restricted areas. We only permit authorized employees to access personal data. These employees are trained on our privacy policies.
The Site may, from time to time, contain links to external sites operated by third parties for your convenience. We have no control of and are not responsible for these third party sites or the content thereof. Once you leave the Site, we cannot be responsible for the protection and privacy of any information which you provide to these third party sites. You should exercise caution and look at the privacy statement for the website you visit.
We may update this Statement. When we do, the changes will be posted on flinkcomm.com.
- Data transfers
You agree that we may transfer your personal data to our overseas offices and/or servers hosted elsewhere in the world for the purpose of processing into our database or to any of the people listed at paragraph 3 above, who may be located elsewhere. If you are located in the European Economic Area (“EEA”) your personal data may be transferred to countries located outside the EEA which do not provide a similar or adequate level of protection to that provided by countries in the EEA. Such transfers will only be made in accordance with applicable laws including where necessary for us to comply with our contractual obligations with you. We will take all steps reasonably necessary to ensure that any personal data are treated securely and in accordance with this Statement.
- Your data privacy rights
Under the Hong Kong Personal Data (Privacy) Ordinance, you have the right:
• to check whether we hold personal data about you and to access such data
• to require us to correct inaccurate data
• to ascertain our policies and practices in relation to personal data and the kind of personal data held by us.
If you are in an EU Member State, subject to certain limitations and/or restrictions, you have the right under the data protection laws in the EU:
• to request access to and rectification or erasure of your personal data;
• to obtain restriction of processing or to object to processing of your personal data; and to the right to data portability.
- Direct Marketing
We intend to use your personal data for direct marketing of our events, services, and products that you may be interested, but we cannot so use your personal data without your consent. We may also transfer your personal data to the transferees listed in paragraph 3 above for their direct marketing purpose. Should you find the use of your personal information acceptable, please indicate your consent to such use by ticking the box below.
Individuals in the EU also have the right to lodge a complaint about the processing of their personal data with their local data protection authority.
If you wish to exercise one of the above mentioned rights, cease marketing communications, and/or raise questions or complaints please contact us at:
Data Privacy Officer
Flink Communications Limited
16 Dai Fat Street, Tai Po Industrial Estate, N.T., Hong Kong
Tel: +852 2789 0282
Fax: +852 3965 0408
Where permitted by law to do so, we may charge a reasonable fee for processing a data access request.
If there is any conflict between the Chinese and English versions of this Statement, the English version prevails.
(Last updated on 27 August 2020)