Introduction

PACE Solutions Limited (“the Company”) is committed to implementation and compliance with the Personal Data (Privacy) Ordinance (“the Ordinance”). The Corporate Data Protection Officer is responsible for coordinating and overseeing compliance with the Ordinance and the upholding of the Data Protection Principles set out in the Ordinance.

This Policy applies to all products and services provided by the Company and sets out how the Company may collect, process, use and disclose your personal data.

In case of any discrepancies between the English and Chinese versions, the English version shall apply and prevail.

Types of Personal Data Possessed by the Company

Personal data regarding customers:

  • (i) name, address, and contact details of customers or potential customers;
  • (ii) occupation, date of birth and nationality of customers, their identity card and/or passport numbers and place and date of issue thereof;
  • (iii) current employer, nature of position, annual salary and other benefits of customers;
  • (iv) details of properties, assets or investments held by customers;
  • (v) details of all other assets or liabilities (actual or contingent) of customers;
  • (vi) information obtained by the Company in the ordinary course of the continuation of the business relationship (for example, when customers lodge insurance claims with the Company or generally communicate verbally or in writing with the Company, by means of documentation or telephone recording system, as the case may be); and
  • (vii) information which is in the public domain.

Personal data regarding employment:

  • (i) name and address, contact details, date of birth and nationality of employees and potential employees and their spouses and their identity card and/or passport numbers and place and date of issue thereof;
  • (ii) additional information compiled about potential employees to assess their suitability for a job in the course of the recruitment selection process which may include references obtained from their current or former employers or other sources;
  • (iii) additional information compiled about employees in the ordinary course of the continuation of the employment relationship which may include records of remuneration and benefits paid to the employees, records of job postings, transfer and training, records of medical checks, sick leave and other medical claims and performance appraisal reports of the employees;
  • (iv) relevant personal data pertaining to former employees may be required by the Company to fulfil its obligations to the former employees and its legal obligations under certain ordinances; and
  • (v) information which is in the public domain.

The Company may hold other types of personal data which it needs in the light of experience and the specific nature of its business.

Accuracy of Personal Data

The Company will ensure the accuracy of all personal data collected and used by the Company. Appropriate procedures are implemented so that all personal data is regularly checked and updated to ensure that it is reasonably accurate having regard to the purposes for which that data is used. If the personal data held by the Company consists of statements of opinion, all reasonably practicable steps are taken to ensure that any facts cited in support of such statements of opinion are correct.

The Company will at all times endeavour to ensure the accuracy of personal data held by the Company, and if such personal data is transferred to third parties, it will notify that third party of any correction to be made.

Retention of Personal Data

The Company will take reasonable and practicable steps to ensure that personal data will not be kept longer than necessary. In general, the Company shall usually hold the related personal data for a period of 7 years after termination of the business relationship or such other periods as prescribed by applicable laws and regulation.

Security of Personal Data

It is the policy of the Company to ensure an appropriate level of protection for personal data in order to avoid unauthorised or accidental access, processing, erasure, loss or other use of that data, commensurate with the sensitivity of the data and the harm that would be caused by occurrence of any of the aforesaid events. It is the practice of the Company to achieve appropriate levels of security by restricting physical access to data, providing secure storage facilities and incorporating security measures into equipment in which data is held. Measures are taken to ensure the integrity, prudence, and competence of persons having access to personal data and personal data is only transmitted by secure means.

Use of Cookies and Third Party Links

The Company may use cookies to improve our internet service to you. Cookies are small data files that are automatically stored on your web browser in your computer that can be retrieved by the Company’s website. Cookies enable the Company’s website to remember you and your preferences when you visit the website and enable us to tailor the website to your needs. The information collected by cookies is anonymous visitor’s personalised settings information and contains no name or address information or any information that will enable anyone to contact you via telephone, e-mail or any other means. No customer personal data is stored in cookies. However, you can disable cookies by changing the settings of your web browser.

The Company’s website may include hyperlinks to third party websites. The Company has no control over the content, accuracy, opinion expressed, and other links provided at these third party websites or how these third party websites deal with your personal data. You should visit these third party websites for details of their privacy policies in relation to their handling of your personal data.

Further enquiries or request regarding the Company’s Privacy Policy such as access, correction or deletion of your personal data held by the Company may be directed to:

XXX Address