Disclaimer

HONG KONG PRIVACY POLICY – WINGATE BUSINESS (effective 1st April 2013)

General

This Privacy Policy sets out the policies and practices of Wingate Business in the collection, use, sharing and protection of customers’ personal information. Wingate Business may update or change this policy and these changes will be posted on Wingate Business’ website.

Collection of Customer’s Personal Information

For the purpose of carrying on Wingate Business’ business including sale, provision, registration and advertisements of Wingate Business’ serviced offices and related products and services, Wingate Business will collect your personal information when you:

1. enter into an agreement for all related services with Wingate Business;
2. enquire as to information about a product or service of Wingate Business;
3. contact Wingate Business with an enquiry or complaint;
4. enter any marketing schemes through Wingate Business’ services;
5. use Wingate Business’ products or services; and
6. visit or browse Wingate Business’ websites.

Types of Personal Data Collected

For the purpose of carrying on Wingate Business’ business including sale, provision, registration and administration of Wingate Business’ serviced office and related products and services, the information that Wingate Business includes but is not limited to the following:

1. your name;
2. correspondence address and/or billing address;
3. account details, including account numbers, service numbers or user accounts;
4. payment details including credit card information, bank account and other banking information;
5. contact details, including contact name and fixed and mobile telephone and email address;
6. your date of birth;
7. information for the verification of your identity including identification number;
8. your preferences for particular products or services;
9. a note or recording of a call that you made to Wingate Business’ hotlines;
10. an email or letter that you sent to Wingate Business; and other records of any contact you have with Wingate Business; and
11. your account information, such as dates of payment, the services you have subscribed to, and any other information relating to your account.

Use of Customers’ Personal Information

Wingate Business may use and analyze your information for the following purposes including but not limited to:

1. for the daily operation of Wingate Business’ services provided to customers;
2. conducting credit checks when required;
3. designing services or products for customers’ use;
4. processing your order and providing the products and services that you have bought from Wingate Business;
5. keeping you updated of Wingate Business’ latest offers or promotions;
6. marketing the following products and services (in respect of which Wingate Business may or may not be remunerated):
7. 1. all products or services by Wingate Business including serviced office space, virtual offices and Internet connectivity;
   2. reward, loyalty or privileges programmes and related products and services; and
   3. products and services offered by Wingate Business’ business partners including travel, dining, entertainment, apparel, health & beauty, education, household, transportation, banking, insurance and other products and services.
8. assisting you with any products or services enquiries, including investigating and resolving service affecting issues and dealing with any billing enquiries you may have;
9. billing you for using Wingate Business’ products or services;
10. analyzing usage of Wingate Business’ products and services by you and other customers so that Wingate Business can further improve Wingate Business’ products and services and/or better tailor the type of products and services presented to customers;
11. carrying out research and statistical analysis and monitoring customer use of Wingate Business’ products and services on an anonymous or depersonalised basis;
12. assisting Wingate Business in fraud or crime prevention;
13. debt tracing, debt recovery and credit management; and
14. contacting you if necessary.

Retention of Personal Data

Wingate Business will destroy any personal data it may hold in accordance with internal policy. Personal data will only be retained as long as Wingate Business needs it unless the personal data is also retained to satisfy any applicable statutory or contractual obligations or for the purpose of investigation, detection and prosecution of crime.

Disclosure and Sharing of Personal Data

All personal data held by Wingate Business will be kept confidential but Wingate Business may disclose information about you to the following parties:

1. companies in the Wingate Business Group;
2. contractors, agents and suppliers who are involved in delivering the products and services you have ordered and used;
3. any banking or financial institutions, charge or credit card issuing companies;
4. credit information or reference bureaus;
5. debt-collection agencies or other debt-recovery organizations;
6. emergency services;
7. professional advisors (including lawyers and auditors);
8. any agent, contractor or third party service provider who provides administrative, telecommunications, computer, payment or other services to Wingate Business in connection with the operation of its business;
9. law-enforcement or government bodies, regulatory bodies, courts or as required by law;
10. any person to whom Wingate Business is under an obligation to make disclosure under the requirements of any law binding on Wingate Business or under and for the purposes of any guidelines issued by regulatory or other authorities with which Wingate Business is expected to comply;
11. third party reward, loyalty and privileges programme providers;
12. business partners of Wingate Business;
13. external service providers (including but not limited to mailing houses, telemarketing and direct sales agents, call centres, data processing companies and information technology companies) that Compass engages for the purposes set out under the section “Use of Customers’ Personal Information”.

Your Privacy Rights

In accordance with the terms of the Personal Data (Privacy) Ordinance (“the Ordinance”), and subject to the exemptions specified in the Ordinance, any customer:

1. has the right to check whether Wingate Business holds any personal data about him or her and has a right to receive copies of such data;
2. has the right to require Wingate Business to correct any personal data relating to him or her which is inaccurate; and
3. has the right to ascertain Wingate Business’ policies and practices in relation to personal data and to be informed of the kind of personal data held by Wingate Business.

In accordance with the terms of the Ordinance, Wingate Business is entitled to charge a reasonable fee for processing a data access request.

Requests for access to personal data, correction of personal data, information relating to the kind of data held and to stop receiving or re-commence receiving direct marketing may be made in writing by email or post to:

Please identify yourself with your name and contact number when writing to Wingate.

Publication of Privacy Policy

This Privacy Policy is subject to change from time to time and any changes will be posted on Wingate Business’ website www.wingate.com.hk

If there is any inconsistency or conflict between the version posted on the website and previous versions, this version shall prevail. If there is any inconsistency or conflict between the English and Chinese versions of this policy, the English version shall prevail.