Privacy Statement
SCHEDULE 1: PRIVACY POLICY STATEMENT
1. Personal Data (Privacy) Ordinance
Tshan Markets complies with the Personal Data (Privacy) Ordinance ('Ordinance'). We take the privacy and security of our customers' personal and financial information very seriously. We understand that trust is the foundation of any successful business, and we are committed to protecting your data and maintaining your confidence in us.
2. Your personal data
It is our policy to protect the privacy of users of the Website. We may, however, collect a very limited amount of your personal data (by 'personal data', we mean information about you or which can be used to ascertain your identity). For example, we may collect some information about you when you visit the Website because your internet provider address needs to be recognised by our server. You will also be invited to provide some information about yourself on various pages of the Website. We do not use 'cookies'.
3. Collection and use of your personal data
Any personal data collected from you on the Website will only be used for the specific purposes mentioned at the time of collection or for purposes directly related to those specific purposes and/or in Tshan Markets' Personal Information Collection Statement.
4. Direct marketing
We would like to use your name and contact details to send you marketing materials about our services and/or related products but we must obtain the consent (or an indication of no objection) of people who become our clients or staff before we can do so. If you do not want to receive our marketing materials, please send an email stating this to [email protected]. More information about this can be found in our Personal Information Collection Statement (Schedule 2).
5. Retention of your personal data
We will retain your personal data only for so long as is necessary for fulfilling the purpose for which they were collected. After that time, your data will be erased or discarded.
6. Disclosure
Your personal data will generally be kept confidential and will not be disclosed to any other person without your consent. However, your data will be used (and disclosed) to third parties for the purposes for which they were collected. Your personal data may also be disclosed where we are required to do so by law. Please also refer to our Personal Information Collection Statement (Schedule 2) as appropriate, for details.
7. Security
We have installed security systems to ensure your personal data are not subject to unauthorised access.
8. Your right of access to and to correct personal data
You are entitled, in accordance with the Ordinance, to check whether we hold data about you and to have access to those data. If any of these data are incorrect or inaccurate, you have the right to correct or update them. Requests for access to or to correct personal data should be addressed to Client Services Team, Tshan Markets Pty Ltd. In accordance with the Ordinance, we are entitled to charge a reasonable fee for processing any data access or correction requests.
SCHEDULE 2: PERSONAL INFORMATION COLLECTION STATEMENT
1.It is often necessary for individual clients or (where clients are businesses, incorporated or otherwise) their individual representatives (including without limitation directors, other officers, employees and staff members of client businesses) (in this statement these individual representatives will, for the sake of brevity, also be referred to generally as “clients” and, in paragraph 4.7(b) below, as "Representatives") to supply Tshan Markets with data about themselves in connection with Tshan Markets' provision of Services to those clients. These data may include copies, and other details, of identity documents, proof of address, other contact details, and proof of authority to engage the services of Tshan Markets.
2. Failure to supply such data may result in Tshan Markets being unable to provide clients with the its services.
3. It is also the case that Tshan Markets collects data from clients in the ordinary course of the vendor-client relationship on an ongoing basis.
4. Purposes of collection and use of personal data:
4.1 The purposes for which personal data relating to a client may be used are as follows:
4.1.1. Obligatory purposes: where a client does not want Tshan Markets to use his personal data for any of the purposes listed in paragraphs 4.1.2 below (inclusive), Tshan Markets will not be able to provide the Services requested
4.1.2. Other general business purposes, including:
4.1.2.1. the provision of services to the client in accordance with terms of business or services agreement with the client and as Tshan Markets may otherwise deem appropriate or necessary;
4.1.2.2. designing services or related products for clients' use;
4.1.2.3. collection of outstanding fees from clients;
4.1.2.4. meeting the requirements to conduct client identification and verification and to make disclosure under the requirements of any law, guideline, code of practice or practice direction binding on, or applicable to, Tshan Markets or any of its branches or associated firms or offices including, but not limited to, any such law, guideline, code or practice direction relating to anti-money laundering and anti-terrorism;
4.1.2.5. purposes specifically provided for in any particular service offered by Tshan Markets;
4.1.2.6. purposes directly related to any of the above;
4.1.3. Marketing: the client's name and contact details (including but not limited to office address, telephone number and email address) provided by the client to Tshan Markets will be used for marketing Tshan Markets' own services and/or related products.
4.2. If a client does not want Tshan Markets to use his personal data for the purposes mentioned in paragraph 4.7 above, he may write to or email the officer named at the end of this statement, indicating his decision and/or return a copy of this statement to that officer.
4.3. Important notes about Tshan marketing:
4.3.1. Clients may at any time send a notice to Tshan Markets requesting Tshan Markets to cease using their personal data for these purposes and Tshan Markets will honour such requests promptly; and
4.3.2. All marketing in relation to Tshan Markets services and related products to Representatives is sent to them in their official capacity as representatives of the client business for whom they work or represent and not in their individual capacity.
5. Exceptions to confidentiality
5.1. any other branch or associated firm or office of Tshan Markets;
5.1.2. If Tshan Markets knows or suspects that any person is involved in drug trafficking, terrorism or any other serious crime, it is obliged to report to a government agency the handling of the proceeds of crime or any property that constitutes terrorist property; in such circumstances, the obligation to report to the authorities may take precedence. Confidentiality obligations on Tshan Markets;
5.1.3. any financial institution, business or professional firm with which the client has or proposes to have dealings related to the services being provided to the client by Tshan Markets;
5.1.4. any actual or proposed assignee of Tshan Markets or transferee of Tshan Markets' rights in respect of the client;
5.1.5. if a client is ever in default of payment of any fees or other moneys to Tshan Markets or otherwise, debt collection agencies;
5.1.6. to third party service providers which provide administrative, technology, marketing or other services to Tshan Markets in relation to its business operations.
5.2.Tshan Markets will not transfer data relating to a client to a third person for that person's marketing activities.
6. Under and in accordance with the terms of the Personal Data (Privacy) Ordinance (“PDPO”) and guidelines issued pursuant thereto, any individual may:
6.1. check whether Tshan Markets holds data about him/her and may request access to such data;
6.2. check whether Tshan Markets holds data about him/her and may request access to such data;
6.3. request Tshan Markets to specify its policies and practices in relation to data and to be informed of the kind of personal data held by Tshan Markets;
6.4. request Tshan Markets to specify its policies and practices in relation to data and to be informed of the kind of personal data held by Tshan Markets;
7. n accordance with the terms of the PDPO, Tshan Markets has the right to charge a reasonable fee for the processing of any data access request.
8. Requests:
8.1. for access to data or correction of data;
8.2. for information regarding policies and practices and kinds of data held are to be addressed IN WRITING to:
Client Services Team, Tshan Markets Pty Ltd
1. Personal Data (Privacy) Ordinance
Tshan Markets complies with the Personal Data (Privacy) Ordinance ('Ordinance'). We take the privacy and security of our customers' personal and financial information very seriously. We understand that trust is the foundation of any successful business, and we are committed to protecting your data and maintaining your confidence in us.
2. Your personal data
It is our policy to protect the privacy of users of the Website. We may, however, collect a very limited amount of your personal data (by 'personal data', we mean information about you or which can be used to ascertain your identity). For example, we may collect some information about you when you visit the Website because your internet provider address needs to be recognised by our server. You will also be invited to provide some information about yourself on various pages of the Website. We do not use 'cookies'.
3. Collection and use of your personal data
Any personal data collected from you on the Website will only be used for the specific purposes mentioned at the time of collection or for purposes directly related to those specific purposes and/or in Tshan Markets' Personal Information Collection Statement.
4. Direct marketing
We would like to use your name and contact details to send you marketing materials about our services and/or related products but we must obtain the consent (or an indication of no objection) of people who become our clients or staff before we can do so. If you do not want to receive our marketing materials, please send an email stating this to [email protected]. More information about this can be found in our Personal Information Collection Statement (Schedule 2).
5. Retention of your personal data
We will retain your personal data only for so long as is necessary for fulfilling the purpose for which they were collected. After that time, your data will be erased or discarded.
6. Disclosure
Your personal data will generally be kept confidential and will not be disclosed to any other person without your consent. However, your data will be used (and disclosed) to third parties for the purposes for which they were collected. Your personal data may also be disclosed where we are required to do so by law. Please also refer to our Personal Information Collection Statement (Schedule 2) as appropriate, for details.
7. Security
We have installed security systems to ensure your personal data are not subject to unauthorised access.
8. Your right of access to and to correct personal data
You are entitled, in accordance with the Ordinance, to check whether we hold data about you and to have access to those data. If any of these data are incorrect or inaccurate, you have the right to correct or update them. Requests for access to or to correct personal data should be addressed to Client Services Team, Tshan Markets Pty Ltd. In accordance with the Ordinance, we are entitled to charge a reasonable fee for processing any data access or correction requests.
SCHEDULE 2: PERSONAL INFORMATION COLLECTION STATEMENT
1.It is often necessary for individual clients or (where clients are businesses, incorporated or otherwise) their individual representatives (including without limitation directors, other officers, employees and staff members of client businesses) (in this statement these individual representatives will, for the sake of brevity, also be referred to generally as “clients” and, in paragraph 4.7(b) below, as "Representatives") to supply Tshan Markets with data about themselves in connection with Tshan Markets' provision of Services to those clients. These data may include copies, and other details, of identity documents, proof of address, other contact details, and proof of authority to engage the services of Tshan Markets.
2. Failure to supply such data may result in Tshan Markets being unable to provide clients with the its services.
3. It is also the case that Tshan Markets collects data from clients in the ordinary course of the vendor-client relationship on an ongoing basis.
4. Purposes of collection and use of personal data:
4.1 The purposes for which personal data relating to a client may be used are as follows:
4.1.1. Obligatory purposes: where a client does not want Tshan Markets to use his personal data for any of the purposes listed in paragraphs 4.1.2 below (inclusive), Tshan Markets will not be able to provide the Services requested
4.1.2. Other general business purposes, including:
4.1.2.1. the provision of services to the client in accordance with terms of business or services agreement with the client and as Tshan Markets may otherwise deem appropriate or necessary;
4.1.2.2. designing services or related products for clients' use;
4.1.2.3. collection of outstanding fees from clients;
4.1.2.4. meeting the requirements to conduct client identification and verification and to make disclosure under the requirements of any law, guideline, code of practice or practice direction binding on, or applicable to, Tshan Markets or any of its branches or associated firms or offices including, but not limited to, any such law, guideline, code or practice direction relating to anti-money laundering and anti-terrorism;
4.1.2.5. purposes specifically provided for in any particular service offered by Tshan Markets;
4.1.2.6. purposes directly related to any of the above;
4.1.3. Marketing: the client's name and contact details (including but not limited to office address, telephone number and email address) provided by the client to Tshan Markets will be used for marketing Tshan Markets' own services and/or related products.
4.2. If a client does not want Tshan Markets to use his personal data for the purposes mentioned in paragraph 4.7 above, he may write to or email the officer named at the end of this statement, indicating his decision and/or return a copy of this statement to that officer.
4.3. Important notes about Tshan marketing:
4.3.1. Clients may at any time send a notice to Tshan Markets requesting Tshan Markets to cease using their personal data for these purposes and Tshan Markets will honour such requests promptly; and
4.3.2. All marketing in relation to Tshan Markets services and related products to Representatives is sent to them in their official capacity as representatives of the client business for whom they work or represent and not in their individual capacity.
5. Exceptions to confidentiality
5.1. any other branch or associated firm or office of Tshan Markets;
5.1.2. If Tshan Markets knows or suspects that any person is involved in drug trafficking, terrorism or any other serious crime, it is obliged to report to a government agency the handling of the proceeds of crime or any property that constitutes terrorist property; in such circumstances, the obligation to report to the authorities may take precedence. Confidentiality obligations on Tshan Markets;
5.1.3. any financial institution, business or professional firm with which the client has or proposes to have dealings related to the services being provided to the client by Tshan Markets;
5.1.4. any actual or proposed assignee of Tshan Markets or transferee of Tshan Markets' rights in respect of the client;
5.1.5. if a client is ever in default of payment of any fees or other moneys to Tshan Markets or otherwise, debt collection agencies;
5.1.6. to third party service providers which provide administrative, technology, marketing or other services to Tshan Markets in relation to its business operations.
5.2.Tshan Markets will not transfer data relating to a client to a third person for that person's marketing activities.
6. Under and in accordance with the terms of the Personal Data (Privacy) Ordinance (“PDPO”) and guidelines issued pursuant thereto, any individual may:
6.1. check whether Tshan Markets holds data about him/her and may request access to such data;
6.2. check whether Tshan Markets holds data about him/her and may request access to such data;
6.3. request Tshan Markets to specify its policies and practices in relation to data and to be informed of the kind of personal data held by Tshan Markets;
6.4. request Tshan Markets to specify its policies and practices in relation to data and to be informed of the kind of personal data held by Tshan Markets;
7. n accordance with the terms of the PDPO, Tshan Markets has the right to charge a reasonable fee for the processing of any data access request.
8. Requests:
8.1. for access to data or correction of data;
8.2. for information regarding policies and practices and kinds of data held are to be addressed IN WRITING to:
Client Services Team, Tshan Markets Pty Ltd
Email：support@tshanmarkets.com
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