Privacy Policy

Last update May, 10th, 2023

The use, disclosure, and processing of your personal information by HK GKK (“we,” or “us”) is explained in this privacy statement.  By using our website and/or applications in the future, you agree to the terms of this Privacy Statement.  This Privacy Policy is subject to modification at any moment, as we retain the right.  We will update this page with any changes to our privacy policy.  If our privacy policy has changed, kindly check back often.  The “Last Updated” date, which is displayed above, will serve as a reminder of any Privacy Policy revisions.

Personal Data We Gather About You and Why It’s Used for Business

The charts below show the many business purposes for which we gather personal data. Please be aware that the precise information about you that we may gather varies based on the context of your interactions with us.  The term “personal information” as used in this privacy statement refers to information that may reasonably be used to directly or indirectly identify, characterize, relate to, or link to a specific consumer or household. The following are excluded from the definition of “personal information”: (i) data that is deidentified or aggregate consumer information; (ii) data that is publicly accessible data or lawfully obtained honest data that is a matter of public concern.

We also gather “sensitive personal information,” as defined below.  Sensitive personal information is defined as personal information that reveals information such as: (a) social security, driver’s license, state identification card, or passport number; (b) account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account; (c) precise geolocation; or (d) racial or ethnic origin, religious or philosophical beliefs, or union membership; (e) the contents of a consumer’s mail, email, and text messages unless we are the intended recipient of the communication; and (f) genetic data.   Sensitive personal information that is publicly available is not deemed sensitive personal information or personal information.

The types of personal information we gathered and have collected in the prior 12 months, the sources from which the personal information was acquired, and the business reason for such collection are listed below.

We sell, share, or disclose personal information about you for business purposes

We do not “sell” your personal information, and we are unaware of any “sale” of personal information of kids under the age of 16, as that word is widely used.  However, we utilize third-party businesses to serve advertising on their sites, such as Meta (Facebook and Instagram), Twitter, LinkedIn, and Google, which may gather your personal information.  Google Analytics is also used to maintain website operation and to improve our website and services. This software may collect information such as your IP address, location, age and gender, browser type and language, operating system, access time, duration of visit, pages you view within our website, search terms you enter and other actions you take while visiting us, the pages you view immediately before and after you access the services, how frequently you use our Services, aggregated usage and performance data, app errors and debugging information, and other information.  By installing the Google Analytics browser add-on, you may opt out of having your activity on our website tracked by Google Analytics.  These firms use the information in line with their privacy rules, which you should read.  Under Hong Kong law, their use of your personal information may constitute a sale.

We may also use your personal information for cross-context behavioral advertising (targeted advertising), including the identifiers, commercial information, internet information, and geolocation mentioned above.

Furthermore, we have shared personal information to our service providers and contractors for the following business objectives in the previous 12 months. 

• Ad Impression Auditing: For auditing reasons relating to counting ad impressions to unique visitors, confirming ad impression placement and quality, and assessing compliance with this specification and other standards.
• Services on Our Behalf: To receive services such as maintaining or servicing accounts, providing customer service, processing, or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing analytic services, providing storage, or performing similar services on our behalf.
• Advertising and Marketing Services: To conduct advertising or marketing on our behalf.
• Research & Development: For internal technical development and demonstration research.
• Quality Control and Product and Service Improvement: To verify, maintain, and enhance our goods and services.

The categories of personal information that we divulge for business purposes are listed in the chart below.

As Required: We reserve the right to disclose personal information when it is required to: (a) comply with legal process; (b) carry out requests from public and governmental authorities; (c) uphold our terms and conditions; (d) safeguard our operations; or (e) defend the rights, privacy, safety, or property of us, you, or others; or (e) enable us to pursue legal remedies or lessen the harm we may suffer.  Additionally, we reserve the right to use personal data in connection with or during any negotiations for any reorganization, merger, sale, joint venture, assignment, transfer, or other disposition of all or any portion of our business, assets, or stock (including in connection with any bankruptcy or similar proceedings).

We only use sensitive personal data for the purposes described in this document.  Other than what is stated below, we never use or disclose sensitive personal information.]

How Long We Keep Your Personal Information – Our Retention Policy

For as long as it is reasonably necessary for us to use the information for the purposes disclosed here and for any other permitted purposes, including the retention of personal information required by any applicable contract, law, or regulation, we will keep each category of your personal information listed above.  The amount, nature, and sensitivity of the personal information, the risk of harm from unauthorized use or disclosure, the purposes for which we process the personal information and whether those purposes can be met by other means and any applicable legal requirements are all taken into account when determining the appropriate retention period.

Verification of the Right to be informed, corrected, and deleted

We will take efforts to confirm your identity before providing you access to your personal information or granting your requests to know, delete, and/or rectify in order to assist preserve your privacy and ensure security while exercising your rights to know, correct, and/or delete. 

Depending on the request you are making and whether you have an account with us or not, our verification process may be different.  The overall description of the verification procedures we employ is as follows:

• Accounts with password protection. We may utilize current authentication procedures to confirm your identity if you have a password-protected account with us, but we will need to re-verify your identity before revealing, amending, or deleting data.  Before granting a request to know or remove information, we may need additional proof (as outlined below) if we believe there has been fraudulent or criminal activity connected to your account.
• Non-Accountholder Verification. We will typically do the following identity verification procedures if you do not have a password-protected account with us or are unable to access one:
  • When you request specific categories of personal information, we shall reasonably confirm your identity by comparing at least two of the data points you supply with the trustworthy data points we keep on file about you.
  • By comparing at least three of the data points you supply with the trustworthy data points we retain, we may plausibly confirm your identity when you ask for particular personal information. Additionally, a certification that the person making the request is that person, or that person’s authorized agent, must be provided and be signed under penalty of perjury.  All signed statements will be kept on file by us.
  • Depending on how sensitive the personal information is and the danger of harm from unauthorized deletion, we will authenticate your identity for requests to rectify or delete personal information to a reasonable or high degree of confidence. When choosing the right standard to use, we shall do so in good faith.

In response to a request for access to or deletion of your personal information, we will let you know if we are unable to verify your identity using any reasonable means, along with a justification.

We may ask the authorized agent to show documentation that you gave the agent signed authorization to submit the request if you use an authorized agent to submit a request to know, delete, or update. As an additional requirement, we could ask you to either (a) directly validate your identification with us or (b) directly affirm that you gave the authorized agent permission to make the request. 

No later than 45 calendar days after receiving a request, we shall reply to requests to know, remove, and/or delete.  We have the right to reject your request if we are unable to verify it within 45 days.  If required, it could take us up to an extra 45 days to reply to your request, but in that case, we’ll give you a heads-up and explain why it might take us longer than 45 days. 

Contact Information

If you have any questions or issues regarding our privacy policies and practices.