Respecting and protecting the privacy of its customers (“you,”) is important to Hong Kong Gemological Research and Authentication Centre Company Limited (“HKGRACE”). References to “we”, “us” and “the Company” shall mean HKGRACE, who controls the collection, holding or use of your personal data. We hope the following policy will help you understand how we collect, use and safeguard your information.
This policy is prepared with reference to the Personal Data (Privacy) Ordinance (Cap.486), Laws of the Hong Kong SAR (“HKSAR”) (the “Ordinance”). Throughout this policy, the meaning of the term “personal data” is the same as defined in the Ordinance unless otherwise specified.
By visiting the websites hongkonggrace.com and/or any other websites, or utilising any online services or mobile applications operated by HKGRACE (“the Sites”), you consent to the practices described in this policy as well as our . Updates to this policy will be posted on this page.
- How we collect and use information
1.1 The Company collects personal information to ensure we can fulfil our service promises and offer you a personal experience online.
1.2 Different levels of personal information may be gathered depending on your usage of our services:
- If you are not a registered user, you are browsing the Sites anonymously as a guest. We will not collect any personal information from you but you may not be able to use all services and features that we offer to registered users.
- You need to input your personal information to register in order for us to process some features and services that we offer to our registered users, such as email updates or requesting information from customer service. We may store some of the data provided for these features and services for such purpose. You have the right to refuse to provide your personal data to us. However, certain services and functions may not be available to you if you do not supply us with data marked with an asterisk (*) on the data collection form.
1.3 We may use your personal details for the following purposes:
- Responding to your enquiries;
- Matching personal information with information you provided to us;
- Marketing our new services, events and/or promotions happening. Please refer to the section “Direct marketing” for more information;
- Communicating with you based on the personal data that you provide to us, such as by phone, email, SMS, smartphone app push notifications or postal mail;
- Analysing trends and behaviour as well as conducting customer surveys to continuously improve our offerings and services;
- Enabling us to meet the requirements to make disclosure under the requirements of any law, regulation or court order binding on us; and
- All purposes directly related to the above.
1.5 We automatically collect anonymous data relating to your online session to gather statistical information on our server’s usage and to help us better meet your demands and expectations. This may include but is not limited to your browser type and version, your operating system, your IP address, access dates and times, your device ID, your mobile network information, your location (with your permission) and/or domain name.
- Third parties
2.1 This policy applies to the Sites, but not to websites, online services or mobile applications maintained by other companies or organizations to which we may link or engage in joint promotions.
2.2 We do not provide any personally identifiable customer information to these advertisers or third-party websites, online services or mobile applications unless your consent is obtained. If you follow a link to any of these websites, online services or mobile applications or submit information to third parties via our websites, online services or mobile applications, please check and read their own privacy notice before submitting your details. Note that we do not accept any responsibility or liability for these policies.
- Security and protection of your information
3.1 We may use your personal information to meet our customer services commitments. Access to such information is protected by physical, electronic and managerial measures and we therefore limit the access to your information to our employees and agents who need it to do their jobs.
3.2 We will never ask you for your personal password either in writing or on the phone. Please take reasonable care in protecting the access to your password and computer and mobile device from any unauthorized use.
4.1 We do not use the Sites to knowingly solicit information from or market to children or young persons under the age of 18.
4.2 If you are under the age of 18, you must let your parent or guardian know about this policy and our [Terms & Conditions] before you use the Sites and its services.
- Disclosure of your personal information
5.1 Your personal information held by the Company will be kept confidential but we may disclose information to the following parties, where such disclosure is necessary to satisfy the purpose, or a directly related purpose, for which the data was collected:
- Any subsidiaries, or affiliates of, or companies controlled by, or under common control with the Company;
- Any person or company who is acting for or on behalf of the Company, or jointly with the Company, in respect of the purpose or a directly related purpose for which the data was provided by you;
- Any other person or company who is under a duty of confidentiality to the Company and has undertaken to keep such information confidential, provided such person or company has a legitimate right to such information; and
5.2 Your personal data may also be disclosed to any person or persons pursuant to any statutory or contractual obligations or as required by court of law, provided such person or persons shall be able to prove the required right/authority to access such information. In addition, your personal data may be disclosed under any of the circumstances described in Part VIII of the Ordinance as exemption from the provisions of the Ordinance.
- Direct marketing
6.1 If you provide us with your personal data, we may use it for direct marketing purpose. We may not use your personal data for such purpose unless we have received your consent. In this connection, please note that:
6.1.1 Your name, salutation, email address, phone number, city of residence, address, postal code, date of birth, other services portfolio information, transaction pattern and behaviour and demographic data held by us from time to time may be used by us in direct marketing.
6.1.2 The following classes of services offered by us may be marketed using your personal data:
- Gemstone testing;
- Customer services in relation to the services above;
- Social networking services;
- Customer reward, loyalty or privilege programs, and related services, products and facilities; and
- Promotional/social events relating to the above matters.
- Our corporate policy
7.1 The Company shall fully comply with the obligations and requirements of the Ordinance. Our officers, management and staff members shall, at all times, respect the confidentiality of and endeavour to keep safe any and all personal data collected and / or stored and / or transmitted and / or used for, or on behalf of, the Company.
7.2 The Company shall endeavour to ensure all collection, storage, transmission and other handling of usage of personal data shall be done in accordance with the obligations and requirements of the Ordinance.
- Your data access rights
8.1 Under the Ordinance, you have the right to:
- check whether we hold data about you;
- request access to such data; and
- request correction of such data.
8.2 You may make the above requests by:
8.2.1 Data Protection Officer
Hong Kong Gemological Research and Authentication Centre Company Limited
Room 8, 2/F, Block A,
Hong Kong Industrial Centre,
489-491 Castle Peak Road,
Cheung Sha Wan, Kowloon
Hong Kong SAR
Tel: (852) 2192 3703
8.3 In accordance with the terms of the Ordinance, we have the right to charge a reasonable fee for processing any data access request.
We reserve the right to amend this policy at any time and will place any such amendments on this page. This policy is not intended to, nor does it, create any contractual rights whatsoever or any other legal rights, nor does it create any obligations on the Company in respect of any other party or on behalf of any party. Nothing in this policy shall limit the rights of data subjects under the Personal Data (Privacy) Ordinance, Chapter 486 of the Laws of HKSAR.