We want you to understand why and how M1615 (“M1615”, “we”, “us” and/or “our”) collects, uses, discloses and/or processes your Personal Data (as defined below) under Hong Kong’s Personal Data Privacy Ordinance (Cap. 486) (the “PDPO”) and the European General Data Protection Regulation (the “GDPR”).

This Privacy Policy (“Policy”) applies to you and all Individuals (as defined below) who provide M1615 with Personal Data or whose Personal Data is otherwise collected, used, processed, stored and/or disclosed by M1615 in connection with and/or for the purposes of its operations.

This Policy supplements but does not supersede or replace any previous consent which you may have provided to M1615, nor does it affect any legal rights that M1615 may have regarding the collection, use, processing and/or disclosure of any Individual’s Personal Data.

M1615 may from time to time update this Policy to ensure that it is consistent with our business needs or to accommodate amendments to applicable legal or regulatory requirements. All updates to this Policy will be published online at https://m1615hk.com/ (the “M1615 Website”). Notification of any material revisions will also be published on the M1615 Website. You shall be deemed to have accepted the Policy as amended by continuing your relationship with M1615 after any amendments have been published on the M1615 Website.

This Policy forms part of the terms and conditions, if any, governing your specific relationship with M1615 (“Terms and Conditions”) and it should be read in conjunction with the Terms and Conditions. In the event of any conflict or inconsistency between the provisions of this Policy and the Terms and Conditions, the provisions of the Terms and Conditions shall prevail to the fullest extent permissible by law.

Definitions: For the purposes of this Policy:

“Individual” (or “you”) means a natural person, whether living or deceased and “Individuals” (and “your”) shall be construed accordingly;

“Personal Data” means data that is capable of identifying an Individual, whether on its own or in conjunction with other data accessible to M1615;

“Personnel” means any Individual engaged under a contract of service with M1615 including permanent or temporary employees as well as trainees and interns engaged by M1615 from time to time; and

“Potential Personnel” means any Individual who has submitted an application to be engaged by M1615 as Personnel.

Purposes for collection, use and disclosure of Personal Data

M1615 will only collect, use and disclose Personal Data from/or related to an Individual that is reasonably considered necessary for the relevant purposes underlying such collection, use or disclosure, which may include but is not limited to the following:

a) Facilitating M1615’s provision of products and services which are used by you;
b) Communicating with you to assist you with your enquiries;
c) Dealing with administrative matters relating to the product and/or services purchased and/or subscribed to by you;
d) Conducting market research and customer satisfaction surveys;
e) Any other purposes that we notify you of at the time of obtaining consent (collectively known as the “Purposes”).

The Purposes for which we may/will collect, use, or disclose your Personal Data depend upon the circumstances at hand. We will notify you of the purpose at the time of obtaining your consent to collect the data.

How M1615 collects Personal Data

Generally, M1615 may collect Personal Data from you in one or more of the following ways or circumstances:

a) Information provided directly: You may be asked to provide Personal Data when you visit or use some parts of our websites and/or services. You do not have to provide us with your Personal Data; however, it could mean that you are not able to access some parts of our website or use our services.
b) Information collected automatically: Some information is collected automatically, such as an IP address and device type, when you visit our websites or use our services. This information is useful to us as it provides us with a better understanding of how you are interacting with our websites and services so that we can continue to provide you with the best experience possible.
c) Information from third parties: The majority of information that we collect is collected directly from you. Some data may be collected from other sources, such as information that is available in the public domain. We use this information to supplement the Personal Data that we have collected from you.

Processing Personal Data

Where we collect Personal Data, we will only process it:

a) To perform a contract with you, or
b) Where we have a legitimate interest to protect the Personal Data which is not overridden by your rights, or
c) In accordance with a legal obligation, or
d) Where we have your consent.

Consent

Unless otherwise authorised under the PDPA, PDPO, GDPR or any other applicable law, M1615 will not collect, use or disclose your Personal Data without your knowledge and consent. M1615 will highlight the Purposes relevant to you, by appropriate means, at the point or time of collection of your Personal Data.

M1615 may obtain your consent by any of the following means:

a) via express provisions in a contract, application form and/or registration form to be signed with or submitted to M1615;
b) via notifications on M1615’s websites;

In so far as any Purpose(s) are intrinsic to the relationship or provision of services, M1615 reserves the right to decline to engage in the relevant relationship or to provide the relevant services to you if you do not consent to M1615’s collection, use or disclosure of your Personal Data for such purposes.

If you:

voluntarily provide Personal Data to M1615 for any specified purpose; use or access M1615’s website(s) or computer network; enter M1615’s premises or use any of the facilities thereon; and/or attend or participate in events or programmes organised by M1615

You will be deemed to have agreed and consented to M1615 collecting, using and/or disclosing their Personal Data in the manner and for the purposes set forth in this Privacy Policy.

If you provide M1615 with Personal Data relating to a third party (e.g. information of his or her spouse or children) for any particular purpose, you represent to M1615 that you have obtained the consent of the relevant third party for M1615 to collect, use or disclose such Personal Data for the relevant purpose.

Disclosure of Personal Data

There may be occasions where we may need to share your Personal Data with third parties. M1615 will disclose your Personal Data only in the following circumstances:

a) to M1615’s third party service providers or agents;
b) to M1615’s auditors and professional advisors;
c) to regulators, law enforcement bodies, government agencies, courts or any other third party to whom disclosure is permitted or required by any applicable law or regulation;
d) to other parties where we have your consent.

Request to Withdraw Consent

You have the right to withdraw your consent to the collection, use and/or disclosure of your Personal Data in the possession of M1615 by submitting your request to M1615’s Data Protection Officer at dpo@m1615hk.com at any time.

We will process your request for the withdrawal of consent within a reasonable period of time from such a request being made. After that time, we will not collect, use and/or disclose your Personal Data in the manner stated in your request.

Your withdrawal of consent could affect the services that we are able to provide to you. Depending on the extent of your withdrawal of consent for us to process your Personal Data, it may mean that we are not able to continue with our existing business relationship.

With regards to data that is collected by cookies, you may disable the use of cookies on your internet browser when accessing M1615’s Website. However, disabling the use of cookies may result in the loss of functionality, restrict your use of the website and/or delay or affect the way in which M1615’s website operates.

Security of Personal Data

M1615 shall make reasonable security arrangements to prevent unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks to Personal Data in its possession.

If M1615 transfers Personal Data outside of Hong Kong, M1615 will take reasonable steps to ensure that such Personal Data transferred receives a standard of protection comparable to the protection received under the PDPA and PDPO and such transfer shall be subject to this Policy.

M1615 will ensure that third parties who receive Personal Data from M1615 protect such Personal Data in a manner consistent with this Policy and not use such Personal Data for any purposes other than those specified by M1615, by incorporating appropriate contractual terms in its written agreements with third parties.

M1615 is not responsible in any way for the security and/or management of Personal Data shared by you with third party websites accessible via links on M1615’s website.

Accuracy of Personal Data

Information voluntarily provided by you to M1615 shall be deemed complete and accurate.

M1615 will take reasonable steps to verify the accuracy of Personal Data received at the point of collection, but you will remain primarily responsible and liable to ensure that all Personal Data submitted by you to M1615 is complete and accurate.

M1615 will also take reasonable steps to periodically verify the Personal Data in its possession, taking into account the scope of its operations. However, you remain responsible for notifying M1615, from time to time, of any applicable changes to your Personal Data. You can amend your Personal Data on the M1615 Platform or you may notify our customer success team of any changes to your Personal Data by email at cs@m1615hk.com, or you may contact the Personal Data Officer by email at dpo@m1615hk.com at any time. M1615 shall not be held liable for any inability on its part to provide services to you if you fail to ensure that your Personal Data submitted to M1615 is complete and accurate.

Access to and correction of Personal Data

You may request (i) access to any Personal Data that is currently in our possession or control; and/or (ii) correction of any data that is currently in our possession or control by contacting us by email at cs@m1615hk.com.

When you request access to your Personal Data within our possession or control, we will seek to provide you with the relevant information within 14 days.

Upon your written request, we will correct any inaccurate Personal Data that is within our possession or control within 14 days.

With your consent, once we have corrected your Personal Data, we will send the corrected Personal Data to all organisations to which your Personal Data was disclosed by M1615 within a year before the correction was made, unless that organisation does not require the corrected Personal Data for any legal or business purpose.

M1615 is not required, under the PDPA and PDPO, to provide access and correction to Personal Data in certain exempted situations as set out in the PDPA or PDPO.

Retention of Data

The length of time that we keep your Personal Data depends on what it is and whether we have an ongoing business need to retain it.

We will only retain your data for as long as we have a business relationship with you and for a period of time afterwards where we have an ongoing business need to retain it, or where we are required by law to retain it.

Upon the expiry of time relating to any business needs or legal requirements to retain your Personal Data we will ensure that your Personal Data is deleted or anonymised.

Making a complaint

You are welcome to contact us if you have any complaint or grievance about how we are handling any Personal Data in our control or possession.

To make a complaint you can:

Contact our Data Protection Officer via email at dpo@m1615hk.com;
Contact us by telephone during our office hours (9:00am to 6:00 pm) at 34269398;
Visit us in person at our office during our office hours (9:00am to 6:00pm).