This policy applies to the collection, use, disclosure and protection of Personal Data, relating to customers of Junius C.T. Lung & Co. Certified Public Accountants (Practising) and all of its subsidiaries and related entities ("JCTL&CO."), customers, suppliers of JCTL&CO. and website users. This policy has been effective since October 19, 2011.

"Personal Data" means any data relating directly or indirectly to a living individual from which it is practicable for the identity of the individual to be directly or indirectly ascertained; and in a form in which access to or processing of the data is practicable. "Data Subject" means an individual who is the subject of Personal Data.

Basic Principles

1. JCTL&CO. will not collect or maintain Personal Data that is not relevant to or not required for the conduct of JCTL&CO.’s business and will take reasonable steps to assure that Personal Data remains accurate.

Personal Data will be treated as confidential, and sufficient internal procedures and controls will be employed to prevent unauthorized access, disclosure, use, copying, modification and destruction of such Personal Data. Personal Data maintained by JCTL&CO. will not be used for purposes that are incompatible with the purposes for which it was collected. Personal Data will not be transferred to any external organization unless we have your consent or are required by law or have previously informed you, and will only be transferred to third parties who have agreed to protect the privacy of Personal Data.

Cookies: your visit to JCTL&CO. sites may be recorded for analysis on the number of visitors to the sites and general usage patterns. Some of this information will be gathered through the use of "cookies", which are small bits of information that are automatically stored on a person's web browser in his computer that can be retrieved by JCTL&CO. sites. Cookies can make JCTL&CO. sites more useful by storing information about your preferences on particular sites, and therefore enabling us to provide more useful features for our site users. Please note that the information collected by "cookies" is anonymous aggregated research data, and contain no name or address information or any information that will enable anyone to contact you via telephone, email or any other means. You may set our browser to disable cookies or inform you when they are set. However, by disabling cookies, you may not be able to take full advantage of JCTL&CO. sites.

Third Parties: JCTL&CO. maintains collaborative relationships with vendors, subcontractors, strategic partners, and others who assist JCTL&CO. and our customers in the conduct of our respective businesses. JCTL&CO. may from time to time transfer Personal Data to these parties to enable them to work with JCTL&CO., but JCTL&CO. requires that they maintain the privacy of Personal Data in a manner satisfactory to JCTL&CO. and consistent with applicable law.

2. JCTL&CO. will deal fairly with each person whose Personal Data is in JCTL&CO. 's custody or control.

Access: You may at any time request for access to, correct and update Personal Data relating to you in any of our records. JCTL&CO. will take steps to correct or delete any inaccuracies in Personal Data pointed out to us, either directly or through making available self-service mechanisms. JCTL&CO. will endeavor to notify recipients of your Personal Data of such changes where required. However, JCTL&CO. may limit access, corrections, or deletions as permitted or required by applicable laws or regulations. JCTL&CO. may establish reasonable rules for providing access to Personal Data, including procedures and fees for responding to Access Requests.

Enforcement: Persons who have questions or believe their Personal Data is not handled in accordance with this Privacy Policy should contact our privacy officer at [email protected].

Legal Requirements

This Privacy Policy is issued by JCTL&CO. in accordance with the Personal Data (Privacy) Ordinance of the Hong Kong Special Administrative Region and applies exclusively to JCTL&CO., its subsidiaries and related entities. JCTL&CO. may change this Privacy Policy from time to time as it deems appropriate. This document describes JCTL&CO. 's privacy policy. However, this policy does not grant or create any additional rights or remedies for the Data Subjects or any additional obligations on the part of JCTL&CO. other than those obligations required by applicable law.