PRIVACY POLICY

1. PRIVACY POLICY STATEMENT

- This statement describes our and also MARKETLIBERTY’s privacy policies and practices in relation to the collection, use, retention, disclosure, transfer, security and access of personal information, which are all made in compliance with and in accordance with the Personal Data (Privacy) Ordinance (Chapter 486 of the Laws of Hong Kong). “MARKETLIBERTY” means the group of companies to which we,MARKETLIBERTY Company Limited, belong.

- We only collect adequate (but not excessive) personal information from you in relation to lawful purposes directly related to our functions or activities. We respect your rights on your personal information.

- Protection of your personal information and use of your personal information properly and legally to serve you better are always our top priorities. We shall use our best endeavor to protect your personal information and keep your personal information accurate and up-to-date. If we have reasonable grounds for believing that your personal information are inaccurate, we shall either stop using such information or erase such information.

- We aim to be accountable, open and transparent in handling your personal information. We shall honor and update your request for access to, correction of or ceasing the use of your personal information in a professional and timely manner and in accordance with the applicable laws.

- We set out in the following paragraphs our PICS (Personal Information Collection Statement) and our Policy Statement on the Use of Personal Data in Direct Marketing. We have tried our very best to present them in a manner that is easily understandable and easily readable.

- If necessary, we shall update our Personal Data (Privacy) Policy and Statement from time to time. Please visit (https://marketliberty.com/privacy-policy) from time to time.

2. PERSONAL INFORMATION COLLECTION STATEMENT

- In order for you to become our member and/or for us to provide services to you, it is necessary for you to provide us with your personal information. Some of them are mandatory, which are basic information we need in order to admit you as our member. The remaining information is optional and is to be provided on a voluntary basis. If you are unable or unwilling to provide us with complete and correct basic personal information, we may not be able to admit you as our member or we may not provide or continue to provide our services to you.

- We shall keep your personal information confidential at all the times. Our policies and practices with respect to the collection, use, retention, disclosure, transfer, security and access of personal information are made in compliance with and in accordance with the laws of the Hong Kong SAR.

- All the personal information provided by you to us and all information relating to your membership with us may be used and retained by us for all or any of the following purposes:

• processing your application for membership;
• providing you with the services under our membership program;
• marketing of goods and/or premiums and/or services by us, please see paragraph 3 below for details;
• providing you with specially selected offers, promotions and benefits by us, please see paragraph 3 below for details;
• communication with you on all matters relating to your membership with us;
• management, operation and maintenance of our membership program;
• designing new or improving existing goods and/or premiums and/or services provided by us;
• investigation of complaints or suspicious transactions;
• prevention or detection of crime;
• disclosure as required by applicable laws and/or rules;
• statistical analysis and/or research;
• enabling us to discharge or comply with usual practices and/or customs in our business sector;
• enabling an actual or proposed assignee or transferee of our business or our rights in respect of your personal information to evaluate the transaction intended; and
• other purposes related or incidental to all or any of the above purposes.

We may for all or any of the purposes set out in sub-paragraph above and paragraph (3) below, disclose and transfer (whether in Hong Kong or aboard) your personal information to third party reward, loyalty or privilege programs providers, co-branding or cross marketing retail partners or charitable or non-profit making organizations, external service providers (which includes but not limited to our agents, contractors, sub-contractors, telecommunication operators, mailing providers, direct sales agents, telemarketing providers, call centers, data processing providers, information technology providers), any other party under a duty of confidentiality to us and any actual or proposed assignees or transferees of our business or our rights in respect of your personal information.

3. USE OF PERSONAL DATA IN DIRECT MARKETING

- We intend to use your personal data for direct marketing.

- We may not so use your personal data unless we have received your consent (which includes an indication of no objection) to the intended use.

- We intend to use the following personal data of yours for marketing goods and/or services and/or subjects mentioned in sub-paragraph below:

• Your name
• Your address
• Your phone number
• Your email address
• Your goods and services consumption pattern
• Other information provided by you

4. YOUR RIGHTS

You have the right to:

- check whether we hold any of your personal information;

- access your personal information held by us;

- require us to correct any personal information which is inaccurate;

- ascertain our policies and practices (from time to time) in relation to personal information and the type of personal information held by us;

- opt-out from allowing us or other parties to use your personal data for direct marketing, please see paragraph 3 above.