Last revised: 2 August 2020
Last updated: 4 February 2021
Privacy Statement Summary
This privacy statement (“Privacy Statement”) explains what information we gather about you, what we use that information for and who we give that information to. It also sets out your rights in relation to your information and who you can contact for more information or queries.
Who this Privacy Statement applies to and what it covers?
This Privacy Statement applies to Yang Chan & Jamison LLP in Hong Kong with registered office address at 806-807, 8/F, One Pacific Place, 88 Queensway, Hong Kong and its affiliates (“Yang Chan & Jamison LLP”, “Deloitte Legal”, “we”, “us” or “our”).
We are committed to protecting your privacy and handling your information in an open and transparent manner.
This Privacy Statement sets out how we will collect, handle, store and protect information about you when you use our website, deloittelegal.com.hk (“Website”), downloadable applications accessed from mobile devices with respect to which this privacy statement is posted or linked (“Mobile Apps”) or any other mode of interacting with you relating to Deloitte communications, such as online or offline newsletters and magazines, that reference this privacy statement (“Communication”).
When we refer to “our Website” or “this Website” in this policy we mean the specific webpages of deloittelegal.com.hk, and to specific webpages with a URL commencing https://www.deloittelegal.com.hk is provided by Yang Chan & Jamison LLP and/or one of its affiliates (collectively, the “Deloitte Network”).
This Privacy Statement also contains information about when we share your personal data with other members of the Deloitte Network and other third parties (for example, our service providers).
In this Privacy Statement, your information is sometimes called “personal data” or “personal information”. We may also sometimes collectively refer to handling, collecting, protecting and storing your personal information as “processing” such personal information.
About other areas of deloittelegal.com.hk
Please note that the other country and regional websites contained within deloittelegal.com.hk are provided by other entities within the Deloitte Network and are not provided by us. Such websites, as well as other websites that may be linked to this Website, are not governed by this Privacy Statement. We encourage visitors to review the Privacy Statements on each of these other websites before disclosing any personal information.
What information we collect?
We may collect personal information when you interact with our Website or Mobile Apps, such as if you choose to register or create a user profile on our Website or a Mobile App (e.g., to gain access to specific content, attend a hosted event, respond to a survey or request communications about specific areas of interest), or otherwise provide it to us. Depending on the specific Communication you are receiving, or the Web page of our Website or Mobile App you are using, such information may consist of your name, current job title, company address, email address, telephone and fax numbers, correspondence with you, which newsletters you subscribe to, and other information you provide to us.
When using a Mobile App, in addition to contact information, we may also collect information relating to your device, including your device model, operating system, browser type, unique device identifier, IP address, mobile phone number, mobile network carrier, location, and the way you are using the Mobile App. The information collected will depend on the functionality of the specific Mobile App you are using. If any other information is collected relating to your use of a Mobile App, such information will be specified in the Mobile App.
We may also collect personal information if you register for our Website or a Mobile App using a third party social network account (e.g., LinkedIn, Facebook, Twitter, Wechat, Weibo). For example, our Website or a Mobile App may allow you to login using your social network account credentials. We may collect the user name associated with that social media account and any information or content you have permitted the social media network to share with us, such as your profile picture, email address, and birthday. The information we collect may depend on the privacy settings you have with the social network site, so please review the Privacy Statement or policy of the applicable social network site. When you access our Website through your social network account, you are authorizing us to collect and use your information in accordance with this privacy statement.
Additionally, we may collect or obtain such data when you use our Website, Mobile Apps and Communication because you give it to us (for example in a form on our Website), because other people give that data to us (for example your employer or adviser, or third party service providers that we use to help operate our business) or because it is publicly available.
Use of personal information collected via our Website, Mobile Apps and Communication
We may use your personal data collected via our Website, Mobile Apps and Communication:
As a visitor, you do not have to submit any personal information in order to use this Website. This Website only collects personal information that is specifically and voluntarily provided by visitors. Such personal information may consist of, but is not limited to, your name, current job title, company address, email address, and telephone and fax numbers.
We may store and maintain any content that you provide, including but not limited to postings on any blogs, forums, wikis and other social media applications and services that we may provide.
The types of personal data that we collect may vary depending on how you use our Website, Mobile Apps and Communication. In some rare circumstances, we might also gather special categories of personal data about you because you volunteer that data to us or we are required to gather that data as a result of legal requirements imposed on us.
We understand the importance of protecting children's privacy. Our Website, Mobile Apps and Communication and services are not designed for, or intentionally targeted at, children. It is not our policy to intentionally collect or store information about children.
How we use information about you?
· to manage and improve our Website, Mobile Apps and Communication;
· to tailor the content of our Website, Mobile Apps and Communication to provide you with a more personalized experience and draw your attention to information about our products and services that may be of interest to you;
· to manage and respond to any request you submit through our Website, Mobile Apps or Communication;
· to allow you to gain access to specific content, attend a hosted event, respond to a survey, or request communications about specific areas of interest;
· for marketing purposes, or to send you promotional materials or communications regarding services provided by entities within the Deloitte Network that we feel may be of interest to you;
· to seek feedback on services provided by entities within the Deloitte Network or for market or other research purposes; and/or
· as part of a corporate transaction such as a sale, divestiture, reorganization, merger or acquisition.
Your personal data may also be used to protect our rights or property and that of our users and, where appropriate, to comply with legal or regulatory process.
The legal grounds we use for processing personal information
We use your personal data for the purposes outlined above because of our legitimate interests in the effective delivery of our Website, Mobile Apps and Communication to visitors or because you have given us your explicit consent to process that data.
We do not usually seek sensitive information (e.g., data relating to race or ethnic origin, religious beliefs, criminal record, physical or mental health, or sexual orientation) from visitors. We will, where necessary, obtain your explicit consent to collect and use such information. We will only provide you with certain marketing materials where we have obtained your explicit consent to provide you with such marketing materials.
Who we disclose your information to?
In connection with one or more of the purposes outlined in the “How we use information about you?” section above, we may disclose details about you to: other members of the Deloitte Network; third parties whether located within or outside our jurisdiction that provide services to us and/or the Deloitte Network; competent authorities (including courts and authorities regulating us or another member of the Deloitte Network); our agents or subcontractors (whether located within or outside our jurisdiction) for the purpose of providing administrative, telecommunications, computer, infrastructure or other support services to us in connection with the operation of our business (as the case may be) and other third parties that reasonably require access to personal data relating to you for one or more of the purposes outlined in the “How we use information about you?” section above.
Our Website or Mobile Apps hosts various blogs, forums, wikis and other social media applications or services that allow you to share content with other users (collectively “Social Media Applications”). Importantly, any personal information that you contribute to these Social Media Applications can be read, collected and used by other users of the application. We have little or no control over these other users and, therefore, we cannot guarantee that any information that you contribute to any Social Media Applications will be handled in accordance with this Privacy Statement.
Where the recipient is not a member of the Deloitte Network, the adequate safeguard might be a data transfer agreement with the recipient based on standard contractual clauses (if applicable) for transfers of personal data to third countries. Further details of the transfers described above and the adequate safeguards used by us or Deloitte Network in respect of such transfers (including copies of relevant agreements) are also available from us by contacting http://www.deloittelegal.com.hk/en/contactus.html
We may also need to disclose your personal data if required to do so by law, a regulator or during legal proceedings.
We may share non-personal, de-identified and aggregated information with third parties for several purposes, including data analytics, research, submissions, thought leadership and promotional purposes.
By providing personal information through this Website, Mobile Apps or Communication, you are consenting to the disclosures described above.
Protection of your personal information
We use a range of physical, electronic and managerial measures to ensure that we keep your personal data secure, accurate and up to date. These measures include:
· education and training to relevant staff to ensure they are aware of our privacy obligations when handling personal data;
· administrative and technical controls to restrict access to personal data on a ‘need to know’ basis;
· technological security measures, including fire walls, encryption and anti-virus software; and
· physical security measures, such as staff security passes to access our premises.
Although we use appropriate security measures once we have received your personal data, the transmission of data over the internet (including by e-mail) is never completely secure. We endeavor to protect personal data, but we cannot guarantee the security of data transmitted to us or by us.
How long we keep your information for?
We will hold your personal data on our systems for the longest of the following periods: (i) as long as is necessary for the relevant activity; or (ii) any retention period that is required by law.
You may have various rights in relation to your personal data. In particular, you may have a right to:
· obtain confirmation that we are processing your personal data and request a copy of the personal data we hold about you;
· ask that we update the personal data we hold about you, or correct such personal data that you think is incorrect or incomplete;
· ask that we delete personal data that we hold about you, or restrict the way in which we use such personal data; and/or
· object to our processing of your personal data.
To exercise any of your rights, or if you have any other questions about our use of your personal data, please contact us at http://www.deloittelegal.com.hk/en/contactus.html
You may also use these contact details if you wish to make a complaint to us relating to your privacy.
In all cases we will treat your requests in accordance with applicable legal requirements.
Right to complain
If you have any questions regarding this privacy statement or you are unhappy with the way we have handled your personal data or any privacy query or request that you have raised with us, please contact webmaster services using the contact us link.
Changes to this Privacy Statement
We may modify or amend this Privacy Statement from time to time.
To let you know when we make changes to this Privacy Statement, we will amend the revision date at the top of this page. The new modified or amended Privacy Statement will apply from that revision date. Therefore, we encourage you to periodically review this statement to be informed about how we are protecting your information.