Privacy Policy

1. Pledge
Right Honour Group Limited, Internal Consent Limited, and Smart Glory Management Limited (“Dock 1A”) pledges to comply with the applicable laws and regulations and, in particular, the Personal Data (Privacy) Ordinance (Cap. 486) of the Laws of Hong Kong Special Administrative Region and the General Data Protection Regulation of the EU.

2. Log Files
You may visit Dock 1A’s website without specifying any personal data. When you visit Dock 1A’s website, the servers of Dock 1A will only collect non-personal data relating to your visits (including your IP address, browser type, access time and your visited pages or similar information) and do not collect your personal data.

3. Use of Cookies
When you browse Dock 1A’s website, cookies will be stored in your computers, mobile phones, tablets or other devices for internal navigation and programming only. You can edit your browser settings to disable cookies but to do so you may not be able to utilize certain functions of Dock 1A’s website.

4. Collection of Information
If you wish to use specific services offered by Dock 1A (e.g. e-newsletters, online transactions), you may be invited to provide your personal data to Dock 1A on a voluntary basis for purposes as stated in the relevant Personal Information Collection Statement provided at the time of such personal data is required. If you do not provide or update accurate information as requested for a specific service, Dock 1A may not be able to provide such service to you.

5. Kinds of Information
Collected You may be required to provide to Dock 1A your personal data, which may, if so necessarily required by the relevant purposes, include your name, e-mail address, address, phone number, business information (company, title, contact information) website, age group, interests, personal preferences, comments and such other information.

6. Main Purposes and Uses of Information Collected
Dock 1A will use your personal data for purposes relating to its [daily operation, administration of accounts and records, research and development, communicating news and information, identification and verification, processing transactions, information and database administration, public relations, disclosure when required by applicable laws or regulations, or orders or requests made by the competent authorities, of the applicable jurisdictions] and all other purposes in connection with or incidental to the aforesaid. When Dock 1A intends to use your personal data for certain specified purposes, such specified purposes will be set out in the relevant Personal Information Collection Statement at the time of such personal data is required.

7. Direct Marketing
If Dock 1A intends to use your personal data (including your name and contact details) collected from you for direct marketing purposes (e.g. to send you marketing communications about news, offers or promotions), Dock 1A will first obtain your consent (or an indication of no objection) before doing so. You may opt-out from receiving marketing communications from Dock 1A at any time, free of charge by:

following the opt-out instructions contained in the communications; or
write to the Personal Data Privacy Officer of Dock 1A at the address listed in “Enquiries” below.

8. Retention of Information
Dock 1A will retain your personal data for a period no longer than necessary for the fulfillment of the purposes for which Dock 1A has collected it and, if applicable, as long as required by the applicable laws or regulations of the applicable jurisdictions. If such purposes no longer apply, or if the retention period required expire, your personal data will be deleted.

9. Disclosure of Information 
Dock 1A may share your personal data with or transfer the same to: –

Dock 1A’s holding companies, subsidiaries, associated companies, fellow subsidiaries and any company in which any of the above has any interest (collectively, the “Group”);
the business associates, partners, agents, contractors, sub-contractors, data processors, suppliers and providers of the Group (collectively, the “Service Providers”) for the prescribed purposes;
the competent authorities of the applicable jurisdictions where overriding legal requirements exist; and
actual or proposed assignee of Dock 1A or the Group or participant or sub-participant or transferee of Dock 1A’s or the Group’s rights.

10. Transfer
Within the scope of the purposes set out above, your personal data may be transferred to third countries (including countries outside the EU and Hong Kong) due to the Group’s and/or the Service Providers’ server locations and in compliance with the requirement of the application laws.  

11. Service Providers
Dock 1A may provide your personal data to the Service Providers. Such Service Providers are or will be required to handle your personal data consistent with the agreements Dock 1A enters into with them as well as this Privacy Policy.

12. Third Party Websites and plug-ins
The website of Dock 1A may from time to time contain linkages to other websites. Dock 1A has no control over your personal data submitted by you, if any, to other websites. This Privacy Policy only applies to the website of Dock 1A. You should read the respective privacy policies of other websites before you submit any personal data to the third parties.

13. Security
The Group has implemented appropriate technical and organizational measures to protect your personal data as far as possible. However, no data transaction over the internet can be guaranteed to be fully secured. Accordingly, despite Dock 1A’s effort to protect your personal data, Dock 1A cannot guarantee or warrant the security of any information you transmit to Dock 1A. You transmit all such information at your own risk.

14. Automated decision making
Dock 1A does not use your personal data for automated decision making which produces legal effects concerning you or similarly significantly affects you.

15. Your rights
You have the right to, in accordance with the applicable laws or regulations of the applicable jurisdictions:

request confirmation from Dock 1A as to whether Dock 1A processes persona data relating to you;
access your personal data held by Dock 1A (if any);
require Dock 1A to correct your personal data that is incorrect, incomplete or inaccurate (if any);
obtain free-of-charge information from Dock 1A on your personal data;
receive a copy of this information, including but not limited to the purposes of the processing, the categories of personal data that are processed, the recipients to whom the personal data has been disclosed or is still be disclosed, the planned retention period (if possible) or the criteria for determining such period;
ascertain Dock 1A’s policies and practices in relation to data and to be informed of the kind of personal data held by Dock 1A;
revoke your consent given to the processing of personal data at any time;
require Dock 1A to erase your personal data on such grounds as prescribed under the applicable laws or regulations of the applicable jurisdictions;
restrict the processing of the personal data by Dock 1A;
object to the processing of the personal data by Dock 1A;
complain to the competent authorities of the applicable jurisdictions;
require Dock 1A to provide information of the origin of your personal data if you have not provided such personal data to Dock 1A;
require Dock 1A to provide information as to transfer of your personal data to a third-party country or to an international organization;
require Dock 1A to send to you or where technically feasible, another data controller, your personal data in a structured, commonly used and machine-readable format.

Nothing in this Privacy Policy shall limit your rights under the applicable laws or regulations of the applicable jurisdictions.

16. Change to Privacy Policy
This Privacy Policy may from time to time be updated, revised and changed. Any change, update or modification will be effective immediately upon being posted on Dock 1A’s website. You agree to be bound by such amended Privacy Policy if you continue to use Dock 1A’s website. Please visit this page periodically to review the most update Privacy Policy.

17. Details of Data Controller
The data controller as specified in the General Data Protection Regulation is 1A Chui Tong Road, Sai Kung, Hong Kong, which, alone or jointly with others, determines the purposes and means of the processing of personal data.

18. Enquiries
If you have any questions or wish to exercise any rights relating to your personal data held by Right Honour Group Limited, Internal Consent Limited, and Smart Glory Management Limited, please contact the Personal Data Privacy Officer of Dock 1A in writing at the following address or by email to customerservice@smartglorymgt.com:  

1A Chui Tong Road, Sai Kung, Hong Kong  

Attn.: Personal Data Privacy Officer  

(Marked Confidential)

19. English Version
If there is any inconsistency or conflict between the English and Chinese version of this Privacy Policy, the English version shall prevail.