- eCredit Management Limited (“eCML”) respects your right to privacy.
- This Privacy Notice explains who we are, how we collect, share and use personal information about you, and how you can exercise your privacy rights. This Privacy Notice applies to personal information that we collect through our websites at creditcheck.com.hk + creditcheck.hk + 網上大搜查.hk + 网上大搜查.hk + ecreditcheck.cn (collectively our“Websites”) as well as personal information that we collect when you use our services ("Services")
- If you have any questions or concerns about our use of your personal information, then please contact us using the contact details provided at the bottom of this Privacy Notice.
- eCML is a service provider in supplying key public information on subject person and entity to our service subscribers to perform their required duties in the areas of Know Your Client (KYC”), Customers Due Diligence (“CDD”), Anti-Money Laundering (“AML”) and/or “Counter-Terrorist Financing (“CTF”).
- For more information about eCML, please see the“About Us”section of our Websites.
- The personal information that we may collect about you broadly falls into the following categories:
- Information that you provide voluntarily
- - Contact information such as your name, address, telephone number, email address, fax number
- - Your billing address
- - credit card information for payment of our service
- Information that we collect automatically
- Information that we obtain from third party sources
- We may disclose your personal information to the following categories of recipients:
- to our group companies, third party services providers and partners who provide data processing services to us (for example, to support the delivery of our Services or to provide functionality on, or help to enhance the security of our Websites), or who otherwise process personal information for purposes that are described in this Privacy Notice or notified to you when we collect your personal information;
- to any competent law enforcement body, regulatory, government agency, court or other third party where we believe disclosure is necessary :
- as a matter of applicable law or regulation;
- to exercise, establish or defend our legal rights; or
- to protect your vital interests or those of any other person;
- to an actual or potential buyer (and its agents and advisers) in connection with any actual or proposed purchase, merger or acquisition of any part of our business, provided that we inform the buyer it must use your personal information only for the purposes disclosed in this Privacy Notice; and
- to any other person with your consent to the disclosure.
- If you are a resident from the European Economic Area, our legal basis for collecting and using the personal information described above will depend on the personal information concerned and the specific context in which we collect it.
- However, we will normally collect personal information from you only :
- where we need the personal information to perform a contract with you;
- where the processing is in our legitimate interests and not overridden by your rights; or
- where we have your consent to do so.
- In some cases, we may also have a legal obligation to collect personal information from you or may otherwise need the personal information to protect your vital interests or those of another person.
- If we ask you to provide personal information to comply with a legal requirement or to perform a contact with you, we will make this clear at the relevant time and advise you whether the provision of your personal information is mandatory or not (as well as of the possible consequences if you do not provide your personal information).
- If we collect and use your personal information in reliance on our legitimate interests (or those of any third party), this interest will normally be to operate our company and communicating with you as necessary to provide our services to you and for our legitimate commercial interest, for instance, when responding to your queries, improving our products and services, undertaking marketing, or for the purposes of detecting or preventing illegal activities. We may have other legitimate interests and if appropriate] we will make clear to you at the relevant time what those legitimate interests are.
- If you have questions about or need further information concerning the legal basis on which we collect and use your personal information, please contact us using the contact details provided under the “How to contact us” heading below.
- All personal data collected and used by eCML are subject to the restrictions of use of such data pursuant to the provisions as stated in the Ordinance. In particular, personal data shall not, without the prescribed consent of the data subject, be used for any new purpose unknown to the person from whom the data were collected and all regulations and guidelines as described under the Data Protection Principle issued by the Office of the Privacy Commissioner for Personal Data are strictly observed by eCML.
- eCML are NOT using and shall NOT use any of your information for any advertising, marketing and/or business soliciting purpose and have not given any consent to any third party using information of our Websites in doing so.
- We use appropriate technical and organisational measures to protect the personal information that we collect and process about you. The measures we use are designed to provide a level of security appropriate to the risk of processing your personal information. Specific measures we use include Secure Socket Layer (SSL) encrypting technology to secure the transmission of your data from your web browser to our internet system.
- Your personal information may be transferred to, and processed in, countries other than the country in which you are resident. These countries may have data protection laws that are different to the laws of your country (and, in some cases, may not be as protective).
- However, we have taken appropriate safeguards to require that your personal information will remain protected in accordance with this Privacy Notice.
- These include implementing the European Commission’s Standard Contractual Clauses for transfers of personal information between our group locations, which require all companies within the eCML group to protect personal information they process from the EEA in accordance with European Union data protection law as well as the Ordinance.
- We retain personal information we collect from you where we have an ongoing legitimate business need to do so (for example, to provide you with a service you have requested or to comply with applicable legal, tax or accounting requirements).
- When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymise it or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.
- You have the following data protection rights:
- If you wish to access, correct, update or request deletion of your personal information, you can do so at any time by contacting us using the contact details provided under the “How to contact us” heading below.
- You can object to processing of your personal information, ask us to restrict processing of your personal information or request portability of your personal information. You can exercise these rights by contacting us using the contact details provided under the“How to contact us”heading below.
- You have the right to opt-out of communications we send you at any time. You can exercise this right by clicking on the “unsubscribe” or “opt-out” link in the emails we send you. In any other case, please contact us using the contact details provided under the “How to contact us” heading below.
- If we have collected and process your personal information with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent.
- You have the right to complain to a data protection authority about our collection and use of your personal information. For more information, please contact your local data protection authority.
- Contact details for data protection authorities:
- The European Economic Area, Switzerland and certain non-European countries (including the US and Canada) are available at : https://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm ; and
- Office of the Privacy Commissioner for Personal Data, Hong Kong : www.pcpd.org.hk
- We will respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws.
- We may update this Privacy Notice from time to time in response to changing legal, technical or business developments. When we update our Privacy Notice, we will take appropriate measures to inform you, consistent with the significance of the changes we make. We will obtain your consent to any material Privacy Notice changes if and where this is required by applicable data protection laws.
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If you have any questions or concerns about our use of your personal information, please contact us:
The Data Controller is Miss Leung.
Introduction
What does eCML do?
What personal information does eCML collect and why?
In order to use our Services, including our Websites, we may ask you to provide personal information voluntarily such as:
We use this personal information to assess whether you are qualified to subscribe our services and to identify whether you have a valid purpose to obtain information from our Websites. The personal information that you are asked to provide, and the reasons why you are asked to provide it, will be made clear to you at the point we ask you to provide your personal information.
When you visit our Websites, we may collect certain information automatically from your device. In some countries, including countries in the European Economic Area, this information may be considered personal information under applicable data protection laws.
Specifically, the information we collect automatically may include information like your IP address, device type, unique device identification numbers, browser-type, broad geographic location (e.g. country or city-level location) and other technical information. We may also collect information about how your device has interacted with our Websites, including the pages accessed and links clicked.
Collecting this information enables us to better understand the visitors who come to our Websites, where they come from, and what content on our Websites is of interest to them. We use this information for our internal analytics purposes and to improve the quality and relevance of our Websites to our visitors.
Some of this information may be collected using cookies and similar tracking technology, as explained further under the heading “Cookies Statement”.
From time to time, we may receive personal information about you from third party sources, but only where we have checked that these third parties either have your consent or are otherwise legally permitted or required to disclose your personal information to us.
The types of information we collect from third parties include data that we gathered and received from public data pools and any public websites and public media. We use the information we receive from these third parties to provide background reference of individuals and maintain the accuracy of the records we hold about you.
In general, we will use the personal information we collect from you only for the purposes described in this Privacy Notice or for purposes that we explain to you at the time we collect your personal information solely and purely for “Know Your Client”, “Anti-Money Laundering” and/or “Counter-Terrorist Funding” purposes as required by the government authorities from time to time basis.
However, we may also use your personal information for other purposes that are not incompatible with the purposes we have disclosed to you (such as archiving purposes in the public interest, scientific or historical research purposes, or statistical purposes) if and where this is permitted by applicable data protection laws.