Last Updated: 25/02/2019
We, Strategic Transactions Limited, (“STL”, “we” or “us”), are committed to protecting the privacy, confidentiality and security of all personal data (i.e. any data (i) relating directly or indirectly to a living individual; (ii) from which it is practicable for the identity of the individual to be directly or indirectly ascertained; and (iii) in a form in which access to or processing of the data is practicable) of and obtained from: –
- every end user of our website www.jrotbart.com or any updates thereof (the “Site”); or
- every user of services provided by us through the Site or through any other channel or through our Account Opening Form (the “Services”).
We hold all such personal data strictly in compliance with the requirements of the Personal Data (Privacy) Ordinance, Cap. 486 of the laws of Hong Kong (the “Ordinance”) with respect to the management of personal data.
In particular, we comply with the six data protection principles laid down in Section 4 and Schedule 1 of the Ordinance which include: –
Principle 1: purpose and manner of collection of personal data (“DPP1”)
Principle 2: accuracy and duration of retention of personal data (“DPP2”)
Principle 3: use of personal data (“DPP3”)
Principle 4: security of personal data (“DPP4”)
Principle 5: information to be generally available (“DPP5”)
Principle 6: access to personal data (“DPP6”)
We are equally committed to ensuring that all our employees uphold these above obligations.
B. Collection and use of personal data (DPP1 & DPP3)
Any personal data collected and held by us will only be used for the following purposes: –
- administrating the Site and the Services;
- marketing the Services;
- marketing any services, products, seminars or conferences and for any analytic software providers authorised by STL in the course of STL carrying on business (the “Transferees”);
- statistical analysis for marketing purposes; and or
- complying with the obligations, requirements or arrangements for using and disclosing data that apply to STL, whether compulsory or voluntary, according to or in connection with any laws, regulations, judgments or court orders binding, applying to or enforceable on STL within or outside Hong Kong existing currently and in the future.
All such personal data will not be used for a purpose other than the purposes mentioned above or a purpose directly related to such purposes unless prior consent is obtained from you by us.
If you decline to provide us with the personal data we require or if you refuse to give us your consent for us to use or provide such personal data to the Transferees for the purposes mentioned above, we may not be able to provide you with the Services.
We may send cookies to your computer. Cookies are strings of information that are sent out by a website and saved in your computer and can be retrieved by the website. We may use session specific cookies and analytic software to automatically collect data about your usage of the Services when you visit the Site or other channels through which the Services are provided (the “Other Channels”). Such data include IP address, click-stream data regarding the portions of the Site or the Other Channels that you visit and the information or services you obtain or input (including domain name, Internet service provider, protocol, browser type, operating system etc.).
You may deactivate the cookies in the settings of your navigation software, but doing so may prevent the Site or the Other Channels from functioning properly and you may not be able to utilize fully all of the features and information on the Site or the Other Channels.
D. Accuracy and duration of retention of personal data (DPP2)
We undertake to take all practicable steps to ensure that personal data is accurate having regard to the purpose(s) for which the personal data is or is to be used (as set out in Section B above).
Where there are reasonable grounds for believing that personal data is inaccurate having regard to the purpose(s) for which the data is or is to be used, we shall take all practicable steps to ensure the data is not used for that purpose(s) unless and until those grounds cease to be applicable to the data, whether by the rectification of the data or otherwise or the data is erased.
Where it is practicable in all the circumstances of the case to know that personal data disclosed to a third party is materially inaccurate having regard to the purpose(s) for which the data is or is to be used by the third party and the data was inaccurate at the time of such disclosure, we shall take all practicable steps to ensure that the third party is informed that the data is inaccurate and is provided with such particulars as will be enable the third party to rectify the data having regard to that purpose(s).
We undertake to take all practicable steps to ensure that personal data is not kept longer than is necessary for the fulfillment of the purposes set out in Section B above. If we engage a data processor, whether within or outside Hong Kong, to process personal data on our behalf, we shall adopt contractual or other means to prevent any personal data transferred to the data processor from being kept longer than is necessary for processing the data.
If STL is to allow its users to make a data deletion request or directly delete his or her account or personal data held by STL, STL should also give details such as how this is to be done and whether the personal data or account so deleted is permanently removed from STL’s system.
Personal data collected and retained by STL and or a Transferee may be stored in and to a place outside Hong Kong as STL and or the Transferee consider appropriate.
E. Handling of sensitive personal data (DPP1 & DPP3)
If STL were to collect sensitive personal data (health, finance, location etc.), STL will explain how it uses, processes, handles and transfers such data. STL would then make it clear whether data subjects have the choice to have such personal data held by STL erased and express their choice not to have the data shared or transferred.
F. Disclosure of personal data (DPP3)
Personal data held by STL will be kept confidential but we may provide personal data to the Transferees for the purposes set out in Section B above and in accordance with applicable data protection laws, rules and regulations.
Such personal data may be transferred by STL or the Transferees in and to a place outside Hong Kong as STL and or the Transferees consider appropriate.
G. Protection measures (DPP4)
We undertake to make our best efforts to ensure the security and confidentiality of the personal data collected by us. We take all practicable steps, and maintains physical, electronic and procedural safeguards to protect the personal data collected against unauthorised or accidental access, processing, erasure, loss or use having particular regard to: –
- the kind of data and the harm that could result if any of those things should occur;
- the physical location where the data is stored;
- any security measures incorporated (whether by automated means or otherwise) into any equipment in which the data is stored;
- any measures taken for ensuring the integrity, prudence and competence of persons having access to the data; and
- any measures taken for ensuring the secure transmission of the data.
If we engage a data processor, whether within or outside Hong Kong, to process personal data on our behalf, we shall adopt contractual or other means to prevent unauthorized or accidental access, processing, erasure, loss or use of the data transferred to the data processor for processing.
Please note that personal data that is transported over an open network, such as the Internet or e-mail, may be accessible anybody. STL cannot guarantee the security or confidentiality of any communication or material transmitted via such open networks. All information or material transmitted via open networks is at your own risk.
H. Outsourcing arrangements (DPP4)
If STL engages a service provider to handle or process personal data (e.g. IT contractors, agencies for clearing payments, survey software/agencies, website analytics service provider, confidential documents disposal service agents etc.), it will state clearly what personal data will be transferred to such third-parties and how such third-parties will ensure protection of the personal data collected.
I. Access and correction of personal data (DPP6)
You have the right to request: –
- ascertain whether STL holds personal data about you;
- access to such personal data; and or
- correction of such personal data,
subject to our right to charge a reasonable fee for processing of your data access request in accordance with the Ordinance.
You should send requests for access to or correction of personal data held by us to: email@example.com
Should you have any enquiries regarding the privacy policies and practices of STL, please contact:
Ms Tatiana Prokofeva, Operations Manager