PRIVACY POLICY OF ALBERT
This Privacy Policy
governs your use of the software application: Albert (the "Mobile
Application") for mobile devices that was created by Think it Twice
Ltd.
Think it Twice Ltd and/or
its subsidiary(ies) and/or affiliates (hereinafter collectively referred to as
the "Company") pledges to meet fully with the
requirements of Cap 486 of the Personal Data (Privacy) Ordinance of the Laws of
the Hong Kong Special Administrative Region. In doing so, the Company will
ensure compliance by its staff to the strictest standards of security and
confidentiality in respect of all personal information and data submitted by
users via albert.today, its sub-domains, and any other websites, media
platforms, or applications including the Mobile Application operated by
the Company (hereinafter collectively referred to as the "Channels")
and the Company will not release such information to anyone without the prior
consent of the relevant user(s) of the Channels (whether registered or not)
(the "User" or the "Users"),
except to the authorised persons listed in Paragraph Disclosure or
Transfer below.
Users are strongly
recommended to read this Privacy Policy carefully in order to understand the
Company's policy and practices with regard to the treatment of personal
information and data provided by Users on the Channels. This Privacy Policy is
applicable to both registered and non-registered Users, and the provisions
herein may be updated, revised, varied, or amended from time to time as the
Company deems necessary.
If Users have questions or
concerns regarding this Privacy Policy, they should first contact the Communication
Team via email: support@youralbert.com.
1
Purpose
of Collection of Personal Data
1.1
In the
course of using the Channels, Users may disclose or be asked to provide
personal information and/or data. In order to benefit from and enjoy the
various services offered by the Channels, it may be necessary for Users to
provide the Company with their personal information and/or data. Although Users
are not obliged to provide the information and/or data as requested on the
Channels, the Company will not be able to render certain services on the
Channels in the event that Users fail to do so.
1.2
This
application is designed to assist the Users at work only. Using the application
beyond workhours is not mandatory by the Channels and the Company and Users who do so are of their own
volition.
1.3
The
Company's purposes for collection of information and data on the Channels
include but are not limited to the following:
(a)
to
perform the daily operation of the services provided to Users;
(b)
to
identify Users who have posted advertisements, materials, messages, photos,
views, or comments or such other information (collectively "Information")
on the Channels;
(c)
to
identify Users who have viewed the Information posted on the Channels;
(d)
to
identify Users who have enjoyed their benefits as members of the Channels by
receiving and using marketing and promotional materials;
(e)
to
allow members of the Channels to enjoy their benefits as members by enrolling
for special events hosted by the Company;
(f)
to
enable the Company to select and present information that matches the needs of
Users or to create personalised contents;
(g)
to
design and provide products and services to Users in relation to the above
purposes;
(h)
to
compile and analyse aggregate statistics about Users' use of the Channels and
service usage by Users for the Company's internal use; and
(i)
to
facilitate the Company use of Users' personal data for purposes relating to the
provision of services offered by the Company and marketing services, special
events, and/or promotions of the Company and/or its clients.
1.4
The
Company strives to collect only personal data which is necessary and adequate
but not excessive in relation to the purposes set out above.
1.5
If the
User is under the age of eighteen (18), the Company strongly recommends
that he or she seeks prior consent from a parent or guardian, who may
contact the responsible personnel of the Company
at support@youralbert.com to register the User as member of the Channels.
1.6
The
content for this application is intended for the internal use of recipients
(current employees of the Company) only and may not be distributed
externally or reproduced for external distribution in any form without express
written permission of Think It Twice Ltd. Upon termination of employment,
access to the application will be terminate immediately without notice. Users
should destroy the application and all copies thereof.
1.7
If the
Company requires the User's personal data for a purpose other than those set
out hereinabove, the Company may request the User's prescribed consent to the
same. If the User is a minor, the prescribed consent should be given by his or
her parent or guardian.
2
Collection
of Personal Data
2.1
The
Company may collect personal information and/or data about the User, such as
his or her name, login ID and password, address, email address, phone number,
age, sex, date of birth, country of residence, nationality, education level,
and work experience that is not otherwise publicly available. Occasionally, the
Company may also collect additional personal information and/or data from the
User in connection with contests, surveys, or special offers.
2.2
Only
duly authorised staff of the Company will be permitted to access the User's
personal information and data, and the Company shall not release such personal
information and data to any third parties save and except for the circumstances
listed out under the Paragraph Disclosure or Transfer entitled
"Disclosure or Transfer of Data".
3
Disclosure
or Transfer of Data
3.1
The
Company agrees to take all practicable steps to keep all personal information
and data of Users confidential and/or undisclosed, subject to the following
conditions.
Generally
speaking, the Company will only disclose and/or transfer the User's personal
information and/or data to the Company's personnel and staff for the purpose of
providing services to the User. However, the Company may disclose and/or
transfer such information and/or data to third parties under the following circumstances:
(a)
where
the information and/or data is disclosed and/or transferred to any third party
suppliers or external service providers who have been duly authorised by the
Company to use such information and/or data and who will facilitate the
services on the Channels, under a duty of confidentiality;
(b)
where
the information and/or data is disclosed and/or transferred to any agents or
associates of the Company who have been duly authorised by the Company to use
such information and/or data;
(c)
where
the Company needs to protect and defend its rights and property;
(d)
where
the Company considers necessary to do so in order to comply with the applicable
laws and regulations, including without limitation compliance with a judicial
proceeding, court order, or legal process served on the Channels; and
(e)
where
the Company deems necessary in order to maintain and improve the services on
the Channels.
3.2
Personal
data collected via the Channels may be transferred, stored, and processed in
any country in which the Company operates. By using the Channels, the User is
deemed to have agreed to, consented to, and authorised the Company to disclose
and/or transfer his or her personal information and data under the
circumstances stated above, as well as to any transfer of information (including
the Information) outside of the User's country.
4
Access
4.1
Any
User is entitled to request access to or make amendments to his or her own
personal information and data kept with the Company by contacting the Customer
Service Representative of the Company or email
to support@youralbert.com.
4.2
In the
event that a User wishes to access or amend his or her personal information and
data, the Company may request him or her to provide personal details in order
to verify and confirm his or her identity. A HKID card number or passport
number or business registration certificate number cannot be amended unless
such data is proved to be inaccurate. The Company is required to respond to a
User's request within 7 days of his or her request and will
endeavor to do so wherever possible.
5
Cookies
and Log Files
5.1
The
Company does not collect any personally identifiable information from any User
whilst they visit and browse the Channels, save and except where such
information of the User is expressly requested. When Users access the Channels,
the Company records their visits only and does not collect their personal
information or data. The Channels' server software will also record the domain
name server address and track the pages the Users visit and store such information
in cookies, and gather and store information like Internet protocol (IP)
addresses, browser type, referring/exit pages, operating system, date/time
stamp, and clickstream data in log files. All these are done without the Users
being aware that they are occurring.
5.2
The
Company and third-party vendors engaged by the Company use the Company's
cookies and third-party cookies, such as the Google Analytics cookies, together
to inform, optimise, and serve marketing materials based on the Users' past
visits to the Channels.
5.3
The
Company does not link the information and data automatically collected in the
above manner to any personally identifiable information. The Company generally
uses such automatically collected information and data to estimate the audience
size of the Channels, gauge the popularity of various parts of the Channels,
track Users' movements and number of entries in the Company's promotional
activities and special events, measure Users' traffic patterns, and administer
the Channels. Such automatically collected information and data will not be
disclosed save and except in accordance with the Paragraph Disclosure or
Transfer entitled "Disclosure or Transfer of Data"
6
Google
Analytics
6.1
Google
Analytics Advertising Features ("Features") are implemented
on the Channels. The Features which the Company has implemented are based
on Google Analytics Demographics and Interest Reporting.
6.2
Google
Analytics is a web analysis service provided by Google which utilises the data
collected to track and examine the use of the Channels to prepare reports on
the Users' activities and share them with other Google services. Google may use
the data collected to contextualise and personalise the marketing materials of
its own advertising network.
6.3
Users
can opt out of Google Analytics here: /
7
Links
to Other Websites, Media Platforms, or Applications
7.1
The
Channels may provide links to other websites, media platforms, or applications
which are not owned or controlled by the Company. Personal information and data
from Users may be collected on these other websites, media platforms, or
applications when Users visit such websites, media platforms, or applications
and make use of the services provided therein. Where and when Users decide to
click on any advertisement or hyperlink on the Channels which grants Users
access to another website, media platform, or application, the protection of
Users' personal information and data which are deemed to be private and
confidential may be exposed in these other websites, media platforms, or applications.
7.2
Non-registered
Users who gain access to the Channels via their accounts in online social
networking tools (including but not limited to Facebook) are deemed to have
consented to the terms of this Privacy Policy, and such Users' personal data which
they have provided to those networking tools may be obtained by the Company and
be used by the Company and its authorised persons in and outside of the User's
country for the purpose of providing services and marketing materials to the
Users. These Users are deemed to have consented to the Company and its
authorised personnel's access and use of their personal data so obtained,
subject to the other provisions of the Privacy Policy.
7.3
This
Privacy Policy is only applicable to the Channels. Users are reminded that this
Privacy Policy grants no protection to Users' personal information and data
that may be exposed on websites, media platforms, or applications other than
the Channels, and the Company is not responsible for the privacy practices of
such other websites, media platforms, or applications. Users are strongly
recommended to refer to the privacy policies of such other websites, media
platforms, or applications.
8
Security
8.1
The
security of Users' personal information and data is important to the Company.
The Company will always strive to ensure that Users' personal information and
data is protected against unauthorised access. The Company has implemented
appropriate electronic and managerial measures in order to safeguard, protect,
and secure Users' personal information and data.
8.2
All
personal data and information provided by Users is only accessible by the
authorised personnel of the Company or its authorised third parties, and such
personnel shall be instructed to observe the terms of this Privacy Policy when
accessing such personal information and data. Users may rest assured that their
personal information and data will only be kept for as long as is necessary to
fulfill the purpose for which it is collected. Registered Users should
safeguard their unique usernames and passwords by keeping them secret and
confidential and by never sharing these details with anyone.
8.3
The
Company follows generally accepted industry standards to protect the personal
information and data submitted by Users to the Channels, both during
transmission and once the Company receives it. However, no method of
transmission over the Internet, or method of electronic storage, is completely
secure. Therefore, while the Company strives to protect Users' personal
information and data against unauthorised access, the Company cannot guarantee
its absolute security.
9
Retention
of Personal Data
Once
the Company has obtained a User's personal information and/or data, it will be
maintained securely in the Company's system. Subject to legal requirements, the
personal information and/or data of Users will be retained by the Company after
deactivation of the relevant service until the User requests the Company in
writing to erase his or her own personal information and/or data from the
Company's database or to terminate his or her membership of the Channels.
10
Changes
in this Privacy Policy
The
Company reserves the right to update, revise, modify, or amend this Privacy
Policy in the following manner at any time as the Company deems necessary and
Users are strongly recommended to review this Privacy Policy frequently. If the
Company decides to update, revise, modify, or amend this Privacy Policy, the
Company will post those changes to this webpage and/or other places the Company
deems appropriate so that Users are aware of what information the Company
collects, how the Company uses it, and under what circumstances, if any, the
Company discloses it.
11
Governing
Law and Jurisdiction
Nothing
in this Privacy Policy shall limit the rights of the User under the Personal
Data (Privacy) Ordinance. This Privacy Policy shall be governed by the laws of
the Hong Kong Special Administrative Region. You agree to submit to the
exclusive jurisdiction of the Hong Kong courts.
For any query, please
contact our communication team via email at support@youralbert.com.