Privacy Policy LEGAL NOTICE This Website has been prepared solely for the purpose of providing information about SeaverCronberg Limited and its services. Privacy Policy 1. Privacy SeaverCronberg Limited ("SeaverCronberg", "We", "Our" or "Us") respects your legal rights of privacy when collecting, storing, using and transmitting personal data and this Privacy Policy explains our privacy practices. It is our policy to pledge to comply with the requirements of the Personal Data (Privacy) Ordinance (Cap. 486) of the Hong Kong Special Administrative Region of the People’s Republic of China. In doing so, we will ensure compliance by our staff to the strictest standards of security and confidentiality. Please read the following carefully to understand our policy and practices regarding how your personal information will be treated. This Privacy Policy applies to all users of this Website and may from time to time be updated, revised, reposted and changed where we deem necessary. Any changes will be posted on this Website. Words or terms used in this Privacy Policy, which are not specifically defined in this Privacy Policy, have the meaning given to them in the Terms of Use. In the event that there is any inconsistency between the English and any other language version of this Privacy Policy, the English version shall prevail. Nothing in this Privacy Policy shall limit the rights of users under the Personal Data (Privacy) Ordinance (Cap. 486) of the Hong Kong Special Administrative Region of the People’s Republic of China. "Personal Data" means any personally identifying information or Sensitive Data (such as but not limited to name, position, contact details, from which it is practicable for the identity of the individual to be ascertained, but also may include other information and data). 2. Collection of Personal Data Generally, SeaverCronberg only collects Personal Data (including but not limited to your name, position, and email address) that are specifically and voluntary provided by you. The purposes for which we may use the data include but are not limited to: a. processing of enquiries of any type; b. participation in surveys; c. communication to advise you of technical updates. SeaverCronberg will not use Personal Data collected through our Website to facilitate unsolicited marketing activities. SeaverCronberg’s intention is not to seek any Sensitive Information through our Website unless being legally required. Sensitive Information includes but is not limited to data relating to: a. race or ethnic origin; b. political opinion; c. religious or other similar beliefs; d. trade union membership; e. physical or mental health; f. sexual life or criminal record. We suggest that you do not provide Sensitive Information of this nature. If you do wish to provide Sensitive Information for any reason, SeaverCronberg accepts your explicit consent to use such information in the ways described in this Privacy Policy or as described at the point where you choose to disclose such information.  In cases where we do collect Personal Data from you, we will: a. inform you that we are doing so and the use that we will make of such Personal Data we collect; and b. inform you how we will store your Personal Data and how you can review, change or delete the Personal Data we have stored. 3. Disclosure We agree to take all practicable steps to keep your Personal Data confidential but we may transfer/assign such data to the following parties: a. any actual or proposed assignee, transferee or successor of our rights in respect of users of this Website; b. our agents, affiliates or associates where we deem necessary to improve our products and services; c. any agent, contractor or third-party service provider who provides administrative, telecommunications, computer or other services to SeaverCronberg in connection with the operation of this Website. Except as expressly mentioned in this Privacy Policy we will not disclose your Personal Data unless we are required to do so by law or we reasonably believe such action being necessary to: a. comply with the law or applicable regulations; b. protect and defend our rights and property; c. protect against misuses or unauthorised use of this Website; or d. protect the personal safety or property of our users or the public. Personal Data collected by SeaverCronberg may be transferred internationally to other SeaverCronberg entities, where it is necessary: a. to meet the purpose for which you have submitted the information; and b. to enable you to be provided with information at a later date which may be of relevance and interest to you based on the nature and purpose of your voluntary enquiry. By submitting Personal Data on SeaverCronberg’s Website, you are providing explicit consent to trans-border transmission of such data collected on this Website for the fulfilment of your voluntary enquiry. 4. Links to Other Websites This Privacy Policy only applies to this Website. If you click on any advertisement or hyperlink directing to another website, you will leave this Website for another location. At any other website, the protection of your privacy and Personal Data as well as your exposure to cookies shall not be our responsibility and you are advised to refer to the Privacy Policy of such other location (if any). 5. Web Logs and Cookies Cookies may be used on some areas of our Website. A cookie is a small software application which allows a website to recognise a previous user and to observe how a user navigates within a website. Cookies are now used as a standard by websites to improve users' navigation experience.  If you are concerned about cookies, most browsers recognise when a cookie is offered, and permits users to opt-out of receiving such. If you are not sure whether your browser has this capability, you should check with the software manufacturer or your internet service provider. It is SeaverCronberg's policy to use cookies to make the navigation of our Website easier for users. In most cases, a user can refuse a cookie and still fully navigate our Website. In order to properly manage our Website and related email services, we may anonymously log information on our operating systems about the number and duration of visits to this Website and identify categories of users by items such as domains and browser types, and to track document identification numbers by way of email acknowledgement or return receipt. These statistics are reported in aggregate to our webmaster and system administrators. This is to ensure that our Website presents the best web experience for users and is an effective information source. This data is logged by SeaverCronberg purely for measuring traffic, site performance and in assisting to resolve any website technical difficulties, as well as to gauge the popularity of various parts of this Website and to gain some general knowledge about our audience. 6. Security SeaverCronberg has implemented generally accepted standards of technology and operational security in order to protect Personal Data from loss, misuse, alteration or destruction. Your Personal Data, however stored, will be accessed only by our authorised employees, agents, affiliates or associates who have agreed to ensure confidentiality of this information. Employees, agents, affiliates or associates designated to handle Personal Data will be instructed to do so only in accordance with this Privacy Policy. Where Personal Data is stored electronically, it will be password-protected (or under some equivalent form of protection) and accessible only by authorised personnel of SeaverCronberg or its agents, affiliates or associates. However, during the time that your Personal Data is being transferred for storage it will not be encrypted and therefore may be accessed by third parties. SeaverCronberg accepts no responsibility for any such access and if you are concerned about such access you should not provide Personal Data. 7. Use of Personal Data in Legal Proceedings If it becomes necessary that we have to take action against you for any reason whatsoever, you expressly agree that the Personal Data provided by you can be relied upon in identifying and taking legal action against you. 8. Data Access and Data Retention When Personal Data is retained, we accept responsibility for keeping a record of the information once a user has submitted such data. We do not accept responsibility for verifying the ongoing accuracy of the content of Personal Data. When practically possible, if we are informed that any Personal Data collected through our Website is no longer accurate, we will make appropriate corrections based on the updated information provided by the authenticated user. You may at any time request such corrections of voluntary submitted Personal Data relating to you in any of our records. Personal Data that is kept by us will be permanently de-identified or destroyed after a reasonable period from the time when it becomes outdated or is no longer required. If you have concerns about how we are handling your Personal Data, you may contact us at any time. You may also ask us to delete you from any active mailing or distribution list. To exercise any of your rights, email your request to the address below or write to us at the address below and marked confidential on the envelope. In response, we may ask you to provide certain details about yourself so that we can be sure you are the person to whom the data refers. We are required to respond to your requests within 90 days and will endeavour to do so wherever possible, but we may charge you a fee for doing so. 9. Communication We welcome your enquiries or comments about our Privacy Policy and any queries or concerns that you may have. Please contact us at: SeaverCronberg Limited The Personal Data Privacy Officer (marked confidential) Level 23, One Island East 18 Westlands Road Quarry Bay Hong Kong Island Hong Kong SAR email: contact@seavercronberg.com 10. Terms of Use Please read the Terms of Use carefully as they apply to your use of this Website. Once you are on this Website, you will be legally bound by the Terms of Use and in consideration of us permitting you to access and use this Website the Terms of Use shall constitute a contract entered into by way of electronic records in accordance with the Ordinance.