Privacy Policy
Last Update: 1 March 2023
We are committed to protecting your privacy. We pledge to fully meet the requirements of the Personal Information (Privacy) Ordinance.
This Privacy Policy describes how We collect, use, store, share and protect the information collected through Kalos.Community (the “Platform”).
This Privacy Policy is incorporated into and subject to our Terms and Conditions. Capitalized words used but not defined in this Privacy Policy have the meaning given to them in the Terms and Conditions.
PLEASE READ THIS PRIVACY POLICY CAREFULLY because it affects your rights under the law.
By using our Platform and/or providing Personal Information to us, you acknowledge that you have read this Privacy Policy, and subject to your explicit consent, which we may separately seek from you as may be required by applicable law, you consent to the terms of this Privacy Policy (including international transfers as set out in this Privacy Policy to countries outside where you are located).
If you do not agree with any part of this Privacy Policy, you may not access or use the Platform. If you have concerns about the categories of Personal Information we collect, please do not provide any Personal Information to us without contacting us.
1. PERSONAL INFORMATION WE COLLECT
1.1. “Personal Information" means any information relating to an identified or identifiable natural person; an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person.
1.2. We collect the following Personal Information that you voluntarily submit to us when you create an Account:
1.2.1. First name, middle name, last name, and email (“Account Information”);
1.2.2. Credit card details and billing address (“Payment Information”); and
1.2.3. Shipping address (“Shipping Information”).
1.3. The categories of Personal Information that we may collect, process, and use may also include:
1.3.1. your interests, preferences, opinions, and feedback; and
1.3.2. your responses to our market surveys and contests.
1.4. To fulfill your request and/or to provide you with the Programme, Service, or Product that you ordered, you need to provide us with the minimum scope of Personal Information that is necessary to complete your request or order. Otherwise, we may not be able to complete your request or order.
1.5. You may voluntarily provide us with additional Personal Information that can help us improve the Platform.
2. PERSONAL INFORMATION FROM OR THROUGH THIRD-PARTY SITES
2.1. When you interact with the Website or your Account through a social media platform or other third-party sites, we may collect the Personal Information that you make available to us on that site, including your account ID or handle. We will comply with the privacy policies of the corresponding social media platform or third-party site. We will only collect and store such Personal Information that we are permitted to collect by the third-party site.
2.2. If you choose to link or sign-in to your Account with or through a social networking service, we and that service may share certain information about you and your activities if you have given your consent.
3. USE OF PERSONAL INFORMATION
3.1. We may collect, process, and use your Personal Information for the following purposes:
3.1.1. to provide or send you any Programme, Product, or Service that you requested or ordered;
3.1.2. to respond to your inquiries;
3.1.3. to mail communications, publications, invitations, and such like as you may select, request, or as we may consider to be relevant to you;
3.1.4. for general market research; and
3.1.5. for registration or enrolment of events and courses organized by our business partners or us;
3.1.6. to manage our business; and
3.1.7. to comply with any requirement of laws, regulation, or any government authority or agency, regulator, or professional body of which we are a member; or
3.1.8. to conduct any action to meet our obligations.
3.2. The following are the legal basis for our use of your Personal Information:
3.2.1. Consent: where you have consented to our use of your Personal Information. You may withdraw your consent to our use of your Personal Information at any time by contacting us.
3.2.2. Contract performance: where we are required to collect and handle your Personal Information to provide you with the services that we have contractually agreed to provide to you.
3.2.3. Legal obligation: where we need to use your Personal Information to comply with our legal obligations.
3.2.4. Vital interests: where we need to process your Personal Information to protect the vital interests of you or another natural person.
3.2.5. Public interest: where we need to process your Personal Information to carry out a task that is in the public interest.
3.2.6. Legitimate interests: where we have a legitimate interest in using your Personal Information, and such purpose is not outweighed by any interests that you may have, or any prejudice that you may suffer, from the relevant use of your Personal Information.
4. MARKETING
4.1. We may send you communications regarding publications, technical updates, upcoming Programmes, Products, and Services, surveys, or activities that may be of interest to you, from time to time.
4.2. As appropriate and where required at the time we collect your information, we will ask you for your consent or otherwise provide you with the opportunity to choose not to receive the materials.
4.3. We may communicate marketing and promotions to you through mail, telephone, or online (including by email, your mobile device, or online banner advertisement).
4.4. We will provide an option to unsubscribe or opt out of further communication on any direct marketing communication sent to you at no charge. If you do not wish to receive further promotional materials from us, you may click unsubscribe from the promotional materials or write to us at cs@kalos.community.
5. SECURITY OF PERSONAL INFORMATION
5.1. We take the security of your Personal Information very seriously. We implement generally accepted standards of technology and operational security to protect personally identifiable information from loss, misuse, alteration, or destruction.
5.2. All Personal Information that you provide to us is secured on our Platform and can be accessed only by authorised personnel who have agreed to maintain the confidentiality of your Personal Information.
5.3. However, the transmission of data over the internet (including by e-mail) is never completely secure. While we endeavour to protect Personal Information, we cannot guarantee the security of data transmitted to or by us.
5.4. If a Personal Information security incident arises, we shall respond to the incident, assess the likely impact of the incident, and take necessary actions to bring the incident under control. Where necessary, we will report to the appropriate authority, notify you of the incident and provide relevant information, as may be required under applicable laws and regulations.
6. SHARING OF PERSONAL INFORMATION
6.1. We do not disclose any Personal Information to any third-parties except as required by law or with your prior consent.
6.2. We may share Personal Information:
6.2.1. for the purpose of providing our Programmes, Products, and Services to you:
6.2.2. when required to facilitate activities or events for which you have registered, including those hosted or co-hosted with a third-party; Personal Information may be collected via event registration forms, and the type of information collected will vary. We may share such information with third-parties for purposes connected to the event;
6.2.3. when we are involved in a merger, acquisition, or sale of all or a portion of its assets; and/or
6.2.4. as otherwise set out in this Privacy Policy.
6.3. We may share Personal Information with the following persons:
6.3.1. any personnel, agent, adviser, auditor, contractor, or service provider who provides services and advice to us in connection with the Platform;
6.3.2. persons in or outside Hong Kong to whom we are required to make disclosure under any law applicable.
6.4. We may also disclose your Personal Information to law enforcement, regulatory and other government agencies and authorities, professional bodies, and other third-parties, as required by and/or in accordance with applicable law or regulation. This may include disclosures outside the country or region where you are located.
7. TRANSFER OF PERSONAL INFORMATION
7.1. When we transfer your Personal Information to third-parties, we do so for the purposes stated in this Privacy Policy, for the administration and maintenance of the Platform and associated systems, and/or for other internal or administrative purposes. We have no control over any act of any third-party. We assume no responsibility for privacy protection against such third-parties. The privacy protection stated in this Privacy Policy does not apply to the information which has been disclosed to any third-party incidental to or in the course of our operation or in providing our services.
8. INTERNATIONAL TRANSFERS
8.1. The Platform has Members, Creators, and third-party service providers located around the world, who may use servers and other resources in various countries and territories to process your information. Thus, your Personal Information may be transferred to and stored outside the country or region where you are located (unless restricted under applicable laws and regulations or specifically agreed by agreement). Such jurisdictions may have different data protection laws. It is our policy to use only third-party service providers that are bound to maintain appropriate levels of security and confidentiality and process Personal Information only as instructed by the Platform. This may include confidentiality agreements with parties that we commission to handle Personal Information, requiring them to process Personal Information in accordance with our requirements, this Privacy Policy, and any other relevant confidentiality and security measures.
9. RETENTION OF PERSONAL INFORMATION
9.1. It is our policy to retain Personal Information only for as long as necessary to fulfill the purposes for which Personal Information is to be used, or as required by law, regulation, or professional standards, and to establish, exercise, or defend our legal rights.
9.2. We keep contact information (such as mailing list information) until a user unsubscribes or requests that we delete that information. If you choose to unsubscribe from a mailing list, we may keep certain limited information about you so that we may fulfill your request.
10. YOUR RIGHTS
10.1. You may have certain rights under applicable laws in relation to the Personal Information we hold about you, including:
10.1.1. Right to enquire and request a copy of certain categories of Personal Information;
10.1.2. Right to update/correct your Personal Information which is inaccurate;
10.1.3. Right to request deletion of your Personal Information;
10.1.4. Right to request cancellation of your Account; and
10.1.5. Right to withdraw consent to processing your Personal Information (to the extent such processing is based on consent and consent is the only permissible basis for processing). Should your consent withdrawal be effective, we will no longer process the corresponding Personal Information. However, your decision to withdraw your consent will not affect the processing of Personal Information previously based on your authorization.
10.2. You may exercise these rights by sending us a request in writing and be sent to us to: Personal Information Controlling Officer, KALOS LIMITED, cs@kalos.community.
10.3. We may charge a fee for your request if permitted by applicable law.
10.4. When requested, and provided that it is practical and commercially feasible to comply with the request, we will reply to your request within 30 days or such time as prescribed under applicable law.
10.5. Should you not be satisfied with how we resolve your concern, you have the right to complain to the data protection authority in your territory.
11. NO SENSITIVE PERSONAL INFORMATION
11.1. We do not collect data relating to physical attributes, race or ethnic origin, religious beliefs, criminal record, physical or mental health, sexual orientation, or other Sensitive Personal Information. We will not collect and process your Sensitive Personal Information unless we have obtained your explicit consent as may be required under applicable law.
11.2. We may, however, collect certain categories of Personal Information that may be regarded as Sensitive Personal Information under relevant laws for purposes of conducting pre-engagement checks and for security purposes.
12. NON-PERSONAL INFORMATION
12.1. Non-Personal Information includes information that does not personally identify you but may include tracking and usage information about your location, demographics, use of the Website and the internet.
12.2. We may collect Non-Personal Information about you, including through cookies and analytics tools. We may also collect personally identifiable information about you either directly from you, or by combining information we collect and maintain through other means (such as Member relationship management) or as we may receive from publicly available sources such as social media or other third-party sites.
13. COOKIE POLICY
13.1. A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.
13.2. We use cookies to record your visit to our Platform and to identify you during your future visits. The cookies collect Non-Personal Information such as browser type, version, operating system, IP address, and the domain name of the server. This Non-Personal Information will be used only to compile general statistics about the number of visitors and use of our Platform.
13.3. The cookies may be saved permanently on your computer. You may disable these cookies, but this may affect your browsing of our Platform.
14. THIRD-PARTY LINKS
14.1. This Privacy Policy applies only to our Platform. Our Website may link to third-party sites that we do not control and which do not operate under our privacy practices. When you link to third-party sites, our privacy practices no longer apply. We assume no responsibility for the information practices of these third-party sites that a user is able to access through our Website. We shall not be responsible for the privacy and security practices or the content of such sites. We encourage visitors to review each third-party site’s privacy policy that you visit.
15. CHILDREN
15.1. We are committed to protecting children’s privacy. We protect the confidentiality and security of children's Personal Information in accordance with relevant applicable laws and regulations. In the case of collecting the Personal Information of a minor, we will only use or publicly disclose such information if we have obtained the explicit consent of the minor's parent or guardian.
16. UPDATES
16.1. We reserve the right to update or amend this Privacy Policy from time to time without notice. Please remember to visit this page from time to time to review any amendments to the Privacy Policy and their effect on your use of the Platform. Your continued use of this Platform implies your acceptance of such amendments.
17. CONTACT US
17.1. If you have any questions, comments, or suggestions, please contact us at KALOS LIMITED, Unit C, 17/F, Silvercorp Int’l Tower, 713 Nathan Road, Kowloon, Hong Kong SAR, or by email to cs@kalos.community.