1. Robinson Consultancy Limited (“Company”) pledges to meet fully with the requirements of the Personal Data (Privacy) Ordinance, Chapter 486 of the Laws of Hong Kong. In doing so, the Company will ensure compliance by its officers and staff to the strictest standards of security and confidentiality in respect of all personal data submitted to the Company by the individual (“User”) to which the personal data relates whether via paper copy or https://www.robinsonconsultant.com.hk/ and its sub-domains (collectively, “Websites”). The Company will not, subject to the terms herein, release the User’s personal data to any third party without the prior consent of the User except to the authorized persons listed under the section headed “Disclosure or Transfer of Data”.
2. Users are strongly recommended to read this Privacy Statement carefully to have an understanding of the Company’s policy and practices with regard to the collection and treatment of personal data provided by the Users. The terms herein may be updated, revised, varied and/or amended from time to time as the Company may deem necessary and/or appropriate.
3. If Users have questions or concerns regarding this Privacy Statement, they should first contact the representative of the Company, whose contact details are set out under the section headed “Enquiries” below.
> Purpose of Collection of Personal Data
4. In the course of using the Websites or the services of the Company, Users may disclose or be asked to provide personal data. In order to have the benefit of and enjoy various services offered by the Websites, it may be necessary for Users to provide the Company with their personal data. Mandatory personal data will be signified to the User. Although Users are not obliged to provide all the personal data as requested, the Company will not be able to render certain services in the event that Users fail to provide the personal data signified as mandatory.
5. The Company’s purposes for collection of personal data are as follows:
a. to assist the Users to find appropriate employment opportunities;
b. to assist potential employers to assess the suitability of the Users for job vacancies;
c. to handle and follow up enquiries, requests and complaints from Users;
d. to contact Users regarding administrative notices and communications relevant to his/her use of the Websites and to respond to Users’ inquiry or request;
e. to verify the identity of Users who have posted advertisements, materials, representations, messages, views or comments or such other information (collectively “Information”) on the Websites;
f. to identify Users who have viewed the Information posted on the Websites; and
g. to prepare industry reports;
h. to obtain statistics about Users to analyze usage of the Websites in order to help its further development for internal use.
6. If a User is under the age of 13, the Company would strongly recommend him/her to seek prior consent from a person with parental responsibility for him/her, e.g. parent or guardian, who may contact the representative of the Company whose contact details are set out under the section headed “Enquiries” for registering the User as member of the Websites
7. The Company strives to only collect personal data which are necessary and adequate but not excessive in relation to the purposes set out herein above.
> Collection of Personal Data
8. The Company may collect the following types of personal data about a User:
b. Hong Kong Identity Card number;
c. Passport number;
d. username and password;
f. email address;
g. phone number;
h. age range;
j. country of residence;
l. education level; and
m. work experience.
9. Occasionally, the Company may also collect additional personal data from a User in connection with contests, surveys, or special offers.
> Disclosure or Transfer of Data
10. The Company may disclose and/or transfer the User’s personal data, including [name, address, email address, phone number, age range, gender, country of residence, nationality, educational level, salary information and work experience], to prospective employers (the “Transferees”) to determine suitability of job vacancies.
11. Personal data collected by the Company may be transferred, stored and processed in places outside Hong Kong.
> Direct Marketing
12. The Company intends to use the User’s name, address, email address and phone number (“Direct Marketing Data”) for direct marketing of:
a. job-hunting and employment agency services offered by Robinson Consultancy Limited;
b. job-hunting and employment agency services offered by Mclaren Consultancy Limited, an employment agency which is within the same group of companies of which Robinson Consultancy Limited belongs;
c. various courses and programs for seeking jobs and career opportunities offered by Robinson Consultancy Limited and/or Mclaren Consultancy Limited;
d. special events for networking hosted by Robinson Consultancy Limited and/or Mclaren Consultancy Limited, including but not limited to courses, workshops, and competitions
e. referral, reward, loyalty or privilege programs and related products and services offered by Robinson Consultancy Limited and/or Mclaren Consultancy Limited;
f. market research participation by means of telephone interviews, face-to-face interviews and focus groups hosted or introduced by Robinson Consultancy Limited and/or Mclaren Consultancy Limited; and
g. volunteer work for non-profit making purposes (collectively, “Marketing Subjects”).
13. The Company intends to provide Direct Marketing Data to the following persons or classes of persons (“Direct Marketing 3rd Parties) for use by that person in direct marketing of the Market Subjects above:
a. Mclaren Consultancy Limited;
b. job-hunting and employment agencies;
c. market research agencies;
d. advertising agencies; and
e. volunteer work providers.
14. The Company may not use and may not provide to the Direct Marketing 3rd Parties the personal data of the User for direct marketing unless the User consents, including by way of an indication of no objection.
15. The provision of the Direct Marketing Data to the Direct Marketing 3rd Parties is for gain (i.e. the Company may receive money or other property in return for providing the Direct Marketing Data).
16. A User may at any time require the Company by way of written notice to the contact the representative of the Company whose contact details are set out under the section headed “Enquiries” (i) to cease to provide his/her Direct Marketing Data to any other person for use by that other person in direct marketing and (ii) to notify in writing any person to whom the data has been so provided to cease to use the data in direct marketing.
> Access to or request for correction of data
17. Any User is entitled to request access to or make amendments to his/her own personal data kept with the Company by contacting the representative of the Company whose contact details are set out under the section headed “Enquiries”. Subject to the paragraph below, Users may alternatively edit, amend or delete his/her personal data at any time by logging into the member section of the Websites.
18. In the event that a User wishes to access or amend his/her personal data, the Company may request him/her to provide personal details in order to verify and confirm his/her identity. The User’s Hong Kong Identity Card number or passport number cannot be amended unless such data is proved to be inaccurate. The Company is required to respond to User’s requests within 40 days of his/her request and will endeavour to do so wherever possible, but the Company reserves the rights to charge the user a reasonable fee for doing so.
19. The Company will not retain your personal data if Users request the Company to cease his/her membership with the Company. We will only keep your personal data for as long as necessary to fulfill the purpose for which the data was collected as set out under the section headed “Purpose of Collection of Personal Data”.
> Cookies and Log Files
20. The Company does not collect any personally identifiable information from any Users whilst they visit and browse the Websites. When Users access the Websites, the Company records their visits only and do not collect their personal information or data. The Websites’ server software will also record the domain name, server, [web] address and track the pages Users visit and store such information in “cookies”, and gather and store information like internet protocol (IP) addresses, browser type, referring/exit pages, operating system, date/time stamp, and clickstream data in log files. All these are done without the Users being aware that they are occurring.
21. The Company does not link the information and data automatically collected in the above manner to any personally identifiable information. The Company generally uses such automatically collected information and data to estimate the audience size of the Websites, gauge the popularity of various parts of the Websites, track Users’ movements and number of entries in the Company’s promotional activities and special events, measure Users’ traffic patterns and administer the Websites. Such automatically collected information and data will not be disclosed save and except in accordance with the section headed “Disclosure or Transfer of Data”.
> Links to Other Websites
22. The Websites may provide links to other websites which are not owned or controlled by the Company. Personal data from Users may be collected on these other websites when Users visit such websites and make use of the services provided therein. Where and when Users decide to click on any advertisement or hyperlink on the Websites which grants Users access to another website, the protection of Users’ personal data which are deemed to be private and confidential may be exposed in these other websites.
24. The Company posts Users’ testimonials on the Websites, which may contain personally identifiable information such as the Users’ names. The Company does obtain the Users’ consent prior to posting the testimonials to post their names along with their testimonials.
25. The security of Users’ personal data is important to the Company. The Company will always strive to ensure that Users’ personal data will be protected against unauthorized access. The Company has implemented appropriate electronic and managerial measures in order to safeguard, protect and secure Users’ personal data.
26. All personal data provided by Users are only accessible by the authorized personnel of the Company or Transferees, and such personnel shall be instructed to observe the terms of this Privacy Statement when accessing such personal data. Users may rest assured that their personal data will only be kept for as long as is necessary to fulfill the purpose for which it is collected. Users should safeguard his/her unique username and password by keeping it secret and confidential and never share these details with anyone.
27. The Company uses a third party service provider to facilitate the electronic payment transactions on the Websites.
28. The Company follows generally accepted industry standards to protect the personal data submitted by Users to the Websites, both during transmission and once the Company receives it. However, no method of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, while the Company strives to protect Users’ personal data against unauthorized access, the Company cannot guarantee its absolute security.
> Retention of Personal Data
29. Once the Company has obtained a User’s personal data, it will be maintained securely in the Company’s system. When the User’s personal data is no longer required for the purposes stated in the “Purpose of Collection of Personal Data” section above, the Company will take all practicable steps to erase or anonymise such personal data unless prohibited under any law or it is in the public interest not to have the data erased. At the written request by the User to the representative of the Company whose contact details are set out under the section headed “Enquiries”, the Company will erase his/her own personal data from the Company’s database.
> Changes in this Privacy Statement
30. The Company reserves the right to update, revise, modify or amend this Privacy Statement in the following manner at any time as the Company deems necessary, so Users are strongly recommended to review this Privacy Statement frequently. If the Company decides to update, revise, modify or amend this Privacy Statement, the Company will post those changes to this webpage and/or other places the Company deems appropriate so that Users would be aware of what information the Company collects, how the Company uses it, and under what circumstances, if any, the Company discloses it.
31. If the Company makes material changes to this Privacy Statement, the Company will notify Users on this webpage, by email, or by means of a notice on the home page of the Company.
Users can contact Jason Fung, the Associate Director of Robinson Consultancy Limited by email at firstname.lastname@example.org or by phone at +852 3695 2689