1.4 This Privacy Statement outlines the information we may collect about you in relation to your use of our Website and related publications and Services, including but not limited to your name, contact details, address, email address, transaction pattern and behavior, background and demographic data ("Personal Data") and how we may use that Personal Data. It also outlines the methods by which we and our service providers may (subject to necessary consents) monitor your online behavior in order to deliver customized advertisements and marketing materials and other tailored services. This Privacy Statement also tells you how you can verify the accuracy of your Personal Data and how you can request that we delete or update it.
2. Information about Us
2.1 Our principal business activities includehosting or accessing the hosted information on HedgeVista platform
2.2 Our address is:
22/F, 3 Lockhart Road,
Wan chai, Hong Kong.
Please note that our address may change from time to time.
2.3 The details of the officer handling Personal Data-related enquiries/matters (“Data Controller”) are as follows:
Name: Devi Chinthireddy
Email address: firstname.lastname@example.org
Tel” +852 54107009
Please note that the details of the Data Controller may change from time to time.
3. Collection of Personal Data
3.1 Our primary goal in collecting Personal Data from you is to give you a convenient and enjoyable customized experience whilst allowing us to provide services and features that most likely meet your needs.
3.2 We collect certain Personal Data from you, which you provide to us when using our Website and/or registering or subscribing for our Services.
3.3 Please note that the Personal Data marked with asterisks is required for our account handling purposes. In the event that you do not supply such Personal Data, we may not be able to provide our Services to you.
3.4 We also collect certain Personal Data from other Group Companies to whom you have given information through their Websites.
3.5 Please note that we do not intend to collect any Personal Data from minors (individuals under eighteen years of age) or mentally incapacitated persons. Minors and mentally incapacitated individuals should not submit any Personal Data to any of the Website, unless their legal guardians provide their written consent for the supply of such information to HedgeVista. Should we discover that any such Personal Data has been delivered to the Website, we will remove that information as soon as possible.
4. Types of Personal Data held and their use
4.1 HedgeVista collects Personal Data such as your name, job title, work and/or home address, telephone number and email address in order to register you for access to certain content and subscriptions. This Personal Data may be supplemented with demographic information you provide through your use of our Website such as your postal area, age, gender, purchasing preferences and interests.
4.3 HedgeVista will only use Personal Data provided by you for the purposes explicitly stated in this Privacy Statement and for the specific purposes indicated at the moment HedgeVista requests you to supply of your Personal Data. Personal Data will not be used for a new or different purpose without your explicit prior written consent (including by way of an opt-in option).
4.4 HedgeVista will retain your Personal Data for as long as it is reasonably necessary to perform the Services.
5. Monitoring use of our Website
5.1 Where we enable you to post information or material on our Website, we may access and monitor any information which you upload or input, including in any password-protected sections. If you are a registered user (e.g. a subscriber or taking a trial), when you log on, this places a cookie on your device. This enables your access to content and services that are not publicly available. Once you are logged on, the actions you take - for example, viewing an article - will be recorded (subject to any necessary consents). We may use technology or a service provider to do this for us. This information may be used for one or more of the following purposes:
6. Direct marketing
6.2 You can give your consent to or opt-out of particular uses of your Personal Data as indicated above by:
(a) indicating your preference at the relevant point on the Website where Personal Data is collected through an opt-out option;
(b) informing us by email, post or phone; or
7. Cookies and similar technologies
7.2 Cookies are pieces of computer code which include a unique reference code that Websites transfer to your device to store and sometimes track information about you. A number of cookies we use last only for the duration of your web session and expire when you close your browser. Other cookies are used to remember you when you return to the Website and will last for longer. Cookies cannot be used to run programs or deliver viruses to your computer. They are uniquely assigned to you and can only be read by a Web server in the domain that issued the cookie.
(a) remember that you have used the Website before; this means we can identify the number of unique visitors we receive to different parts of the Website. This allows us to make sure we have enough capacity for the number of users that we get and make sure that the Website run fast enough;
(b) remember your login session so you can move from one page to another within the Website;
(c) store your preferences, your username and/or password so that you do not need to input these every time you visit the Website;
(d) customize elements of the layout and/or content of the pages of the Website for you;
(e) record activity on our Website so that we understand how you use our Website, which enables us to better tailor our content, services and marketing to your needs;
(f) collect statistical information about how you use the Website so that we can improve them;
(g) gather information about the pages on the Website that you visit, and also other information about other websites that you visit, so as to place you in a “market segment”. This information is only collected by reference to the IP address that you are using, but does include information about the country and city you are in, together with the name of your internet service provider. This information is then used to place interest-based advertisements on the Website which may be relevant to your market segment based on computer algorithms;
(h) email tracking, so that we can better understand our users’ needs, for example, to see which links are the most popular in newsletters, and to log and follow up responses to our marketing messages.
7.4 Some of the cookies used by our Website are set by us, and some are set by third parties who are delivering services (such as interest based advertising directed at your market segment) on our behalf.
7.5 Most web browsers automatically accept cookies but, if you prefer, you can change your browser to prevent that or to notify you each time a cookie is set. Please note however, that by blocking, deleting or turning off cookies used on the Website you may not be able to take full advantage of the Website’s features.
8.3 Your Personal Data may also be sold to third parties in the form of lists and directories, but only after obtaining written permission from you (including in the form of opt-in options on our Website) in accordance with the provisions above.
8.4 We may transfer, sell or assign any of the information described in this Privacy Statement to third parties as a result of a sale, merger, consolidation, change of control, transfer of assets or reorganisation of our business.
10. Transfers outside of Hong Kong
10.1 Services on the Internet are accessible globally, so collection and transmission of Personal Data is not always limited to one country. HedgeVista may transfer your Personal Data, for the purposes listed above, to Group Companies, service providers or other third parties which may be located in countries outside of Hong Kong, whose laws may not give the level of protection to Personal Data as within Hong Kong. This will include transfers to third parties who provide us with email and marketing services. Whenever we conduct any transfers we will take all steps reasonably necessary to ensure that your Personal Data is treated securely and in accordance with this Privacy Statement.
11. Confidentiality and Security of Your Personal Data
11.1 We are committed to keeping the Personal Data you provide us secure. We have implemented information security policies, rules and technical measures to protect all Personal Data that is reasonably under our control from:
(a) unauthorised access;
(b) improper use or disclosure;
(c) unauthorised modification;
(d) unlawful destruction or accidental loss.
11.2 The transmission of information via the Internet is not completely secure. Although we will do our best to protect your Personal Data, we cannot guarantee the security of your Personal Data transmitted to our Website. Every transmission is at your own risk. Once we have received your Personal Data, we will use strict procedures and commercially reasonable security features described above to try to prevent unauthorised access.
11.3 All our employees, contractors and data processors (i.e. those who process your Personal Data on our behalf, for the purposes listed above), who have access to, and are associated with the processing of your Personal Data, are obliged to keep the information confidential and not use it for any other purpose than to carry out the services they are performing for us.
12. How to Access, Update and Erase your Personal Data
12.1 Under the Ordinance you have the right:
12.3 Upon your filing of such Personal Data request (“Personal Data Access Request”), we will provide you with a readable copy of all Personal Data which we keep about you. We may require proof of your identity and may charge a small fee (not exceeding the statutory maximum fee that can be charged) to cover administration and postage.
12.4 All Personal Data Access Requests must either be in the English or Chinese language.
12.5 HedgeVista will take all reasonable measures necessary to comply with your Personal Data Access Request within 40 days from the receipt of the same, by:
(ii) supplying a copy of the Personal Data; or
(b) if HedgeVista does not hold any Personal Data, by informing you in writing that it does not hold the same.
12.6 HedgeVista may refuse to comply with a Personal Data Access Request where:
13. How to report (suspected) breaches of your Personal Data’s privacy
14. Governing law and jurisdiction
14.1 Nothing in this Privacy Statement shall limit your rights under the Ordinance. This Privacy Statement shall be governed by the laws of Hong Kong. You agree to submit to the exclusive jurisdiction of the courts of Hong Kong.
15. Changes to this Privacy Statement
15.1 We will occasionally update this Privacy Statement to reflect new legislation or industry practice, group company changes and customer feedback. We encourage you to review this Privacy Statement periodically to be informed of how we are protecting your Personal Data.
This Privacy Statement was last updated in February 2018.