Last updated December 2021
ADMAZES1 is dedicated to protecting the confidentiality and privacy of information entrusted to it. As part of this fundamental obligation, ADMAZES is committed to the appropriate protection and use of personal information (sometimes referred to as “personal data”, “personally identifiable information” or “PII”) that has been collected online.
Generally, our intent is to collect only the personal information that is provided voluntarily by online visitors for the purpose of offering information and/or services to those individuals or offering information about employment opportunities. Please review this privacy statement (“Privacy Statement”) to learn more about how we collect, use, share and protect the personal information that we have obtained.
1. Collection and use of personal information
1.1 What information we collect
1.2 The legal grounds we have to use your personal
information
1.3 Automatic collection of personal information
1.4 Social media widgets and applications
2. Sharing and transfer of personal information
2.1 Transfers to third parties
2.2 Transfer within the global organisation of ADMAZES firms
5. Data security and integrity
8. Policy questions and enforcement
1. Collection and use of personal information
1.1 What information we collect
We obtain personal information about you if you choose to provide it — for example, to contact mailboxes or to register for certain services. In some cases, you may have previously provided your personal information to ADMAZES (if, for example, you are a former employee). If you choose to register or login to a ADMAZES website using a third party single sign-in service that authenticates your identity and connects your social media login information (e.g., LinkedIn, Google, Twitter or microblog, WeChat or QQ) with ADMAZES, we will collect any information or content needed for the registration or log-in that you have permitted the social media provider to share with us, such as your name and email address for the purposes above mentioned. Other information we collect may depend on the privacy settings you have set with your social media provider, so please review the privacy statement or policy of the applicable service.
By registering and/or submitting personal information to ADMAZES, you are also acknowledging that ADMAZES may use this information in accordance with this Privacy Statement. Your personal information is not used for other purposes, unless we obtain your permission, or unless otherwise required or permitted by law or professional standards. For example, if you register to a ADMAZES website and provide information about your preferences we will use this information to personalise your user experience. Where you register or login using a third-party single user sign-in we may also recognize you as the same user across any different devices you use and personalise your user experience across other ADMAZES sites you visit. If you send us a resume or curriculum vitae (CV) to apply online for a position with ADMAZES, we will use the information that you provide to match you with available ADMAZES job opportunities.
In some cases where you have registered for certain services, we may store your email address temporarily until we receive confirmation of the information you provided via an email (i.e. where we send an email to the email address provided as part of your registration to confirm a subscription request) or required by the applicable law.
This Privacy Statement also covers other means by which we collect information. For example, it also covers how we collect information from in person discussions, telephone conversations, and through non-electronic communications (i.e., collection through means other than ADMAZES’s online systems).
1.2 The legal grounds we have to use your personal information
ADMAZES generally collects only the personal information necessary to fulfil your request. Where additional, optional information is sought, you will be notified of this at the point of collection. The relevant data privacy laws in the Peoples’ Republic of China, Hong Kong SAR, Macau SAR and European Union General Data Protection Regulation (“GDPR”) where applicable, allows us to process personal information, so long as we have a ground under the law to do so. It also requires us to tell you what those grounds are. As a result, when we process your personal information, we will rely on one of the following processing conditions:
· Performance of a contract: this is when the processing of your personal information is necessary in order to perform our obligations under a contract entered with you;
· Legal obligation: this is when we are required to process your personal information in order to comply with a legal obligation, such as keeping records for tax purposes or providing information to a public body or law enforcement agency;
· Legitimate interests: we may process information about you where it is in our legitimate interest in running a lawful business to do so in order to further that business, so long as it doesn’t outweigh your interests; or
· Your consent: we may occasionally ask you for specific and separate permission to process some of your personal information, and we will only process your personal information
in this way if you agree for us doing so. You may withdraw your consent at any time by contacting ADMAZES at info@Admazes.com.
ADMAZES only collects “sensitive” personal information when the relevant individuals voluntarily provide us with this information or where such information is required or permitted to be collected by law or professional standards.
Sensitive information includes personal information regarding a person’s race, ethnicity, political beliefs, trade union membership, religious or similar beliefs, physical or mental health, sexual life or criminal record, biometric identification, specific identity, medical health, financial account and whereabouts and tracks.
Please use your discretion when providing sensitive information to ADMAZES. Under any circumstances, you should not provide yours or any third parties’ sensitive personal information to ADMAZES unless we shall separately notify you (and these third parties) and you (and these third parties) have given us your (and these third parties’) explicit consent for ADMAZES to use or process your (and these third parties’) sensitive personal information for legitimate and necessary business purposes and you (and these third parties) have also consented for us to the transfer and store such sensitive personal information in ADMAZES databases.
If you have any questions about whether the provision of sensitive information to ADMAZES is, or may be, necessary or appropriate for particular purposes, please contact ADMAZES at info@Admazes.com.
1.3 Automatic collection of personal information
In some instances, ADMAZES and its service providers uses cookies, web beacons and other technologies to automatically collect certain types of information when you visit us online, as well as through emails that we may exchange. The collection of this information allows us to customise your online experience, improve the performance, usability and effectiveness of ADMAZES’s online presence, and to measure the effectiveness of our marketing activities. If you have subscribed to our marketing activities, you shall have the right to “Opt-Out” anytime if you do not wish to receive any future marketing materials from the relevant ADMAZES websites.
1.3.1 IP addresses
An IP address is a number assigned to your computer whenever you access the internet. It allows computers and servers to recognise and communicate with one another. IP addresses from which visitors appear to originate may be recorded for IT security and system diagnostic purposes. This information may also be used in aggregate form to conduct website trend and performance analysis.
1.3.2 Cookies
Cookies may be placed on your computer or internet-enabled devices whenever you visit us online. This allows the site to remember your computer or device and serves the purposes notified in this Privacy Statement.
On some of our websites, a notification banner will appear requiring your consent to collect cookies. If you do not provide consent, your computer or internet-enabled device will not be tracked for marketing-related activities. A secondary type of cookie referred to as “user-input” cookies may still be required for necessary functionality. Such cookies will not be blocked through the use of this notification banner. Your selection will be saved in a cookie and is valid for a period of 90 days. If you wish to revoke your selection, you may do so by clearing your browser’s cookies.
Although most browsers automatically accept cookies, you can choose whether or not to accept cookies via your browser’s settings (often found in your browser’s Tools or Preferences menu). You may also delete cookies from your device at any time. However, please be aware that if you do not accept cookies, you may not be able to fully experience some of our websites’ features.
Further information as about managing cookies can be found in your browser’s help file or through sites such as www.allaboutcookies.org.
Other third-party tools and widgets maybe used on our individual web pages to provide additional functionality. Use of these tools or widgets may place a cookie on your device to make their service easier to use, and ensure your interaction is displayed on our webpages properly.
Cookies by themselves do not tell us your email address or otherwise identify you personally. In our analytical reports, we may obtain other identifiers including IP addresses, but this is for the purpose of identifying the number of unique visitors to our websites and geographic origin of visitor trends, and not to identify individual visitors.
BY NAVIGATING ON OUR WEBSITES OR ENTERING YOUR LOGIN DETAILS TO ACCESS AREAS RESERVED FOR REGISTERED USERS, YOU AGREE THAT WE CAN PLACE THESE COOKIES ON YOUR COMPUTER OR INTERNET ENABLED DEVICE.
1.3.3 Google Analytics
ADMAZES uses Google Analytics. More information about how Google Analytics is used by ADMAZES can be found here: https://www.google.com/analytics/terms/us.html
To provide website visitors with more choice on how their data is collected by Google Analytics, Google have developed the Google Analytics Opt-out Browser Add-on. The add-on communicates with the Google Analytics JavaScript (ga.js) to indicate that information about the website visit should not be sent to Google Analytics. The Google Analytics Opt-out Browser Add-on does not prevent information from being sent to the website itself or to other web analytics services.
1.3.4 Web beacons
A web beacon is a small image file on a webpage that can be used to collect certain information from your computer, such as an IP address, the time the content was viewed, a browser type, and the existence of cookies previously set by the same server. ADMAZES only uses web beacons in accordance with applicable laws.
ADMAZES or its service providers may use web beacons to track the effectiveness of third-party websites that provide us with recruiting or marketing services or to gather aggregate visitor statistics and manage cookies.
You have the option to render some web beacons unusable by rejecting their associated cookies. The web beacon may still record an anonymous visit from your IP address, but cookie information will not be recorded.
In some of our newsletters and other communications, we may monitor recipient actions such as email open rates through embedded links within the messages. We collect this information to gauge user interest and to enhance future user experiences.
1.3.5 Location-based tools
ADMAZES may collect and use the geographical location of your computer or mobile device. This location data is collected for the purpose of providing you with information regarding services which we believe may be of interest to you based on your geographic location, and to improve our location-based products and services.
1.4 Social media widgets and applications
ADMAZES websites may include functionality to enable sharing via third party social media applications, such as the Facebook, microblog, WeChat Like button and QQ, Twitter widget. These social media applications may collect and use information regarding your use of ADMAZES websites (see details on ‘Social Sharing’ cookies above). Any personal information that you provide via such social media applications may be collected and used by other members of that social media application and such interactions are governed by the privacy policies of the companies that provide the application. We do not have control over, or responsibility for, those companies or their use of your information.
In addition, ADMAZES websites may host blogs, forums, crowd-sourcing and other applications, or services (collectively “social media features”). The purpose of social media features is to facilitate the sharing of knowledge and content. Any personal information that you provide on any ADMAZES social media feature may be shared with other users of that social media feature (unless otherwise stated at the point of collection), over whom we may have limited or no control.
1.5 Minors
ADMAZES understands the importance of protecting minors’ privacy, especially in an online environment. In particular, our sites are not intentionally designed for or directed at minors under the age of 18. It is our policy never to knowingly collect or maintain information about anyone under the age of 18, except as part of an engagement to provide professional services.
2. Sharing and transfer of personal information
2.1 Transfers to third parties
We do not share personal information with unaffiliated third parties, except as necessary for our legitimate professional and business needs and to the extent permitted by law, to carry out your requests, and/or as required or permitted by law or professional standards. This would include:
· Our service providers: ADMAZES work with reputable partners, service providers or agencies so they can process your personal information on our behalf. ADMAZES will only transfer personal information to them when they meet our strict standards on the
processing of data and security. We only share personal information that allows them to provide their services.
· If we are reorganised or sold to another organisation: ADMAZES may also disclose personal information in connection with the sale, assignment, or other transfer of the business of the site to which the data relates;
· Courts, tribunals, law enforcement or regulatory bodies: ADMAZES may, to the extent permitted by the local laws or subject to the fulfillment of the regulatory requirements of the applicable laws, disclose personal information in order to respond to requests of courts, tribunals, government or law enforcement agencies or where it is necessary or prudent to comply with applicable laws, court or tribunal orders or rules, or government regulations.
· Audits: disclosures of personal information may also be needed for data privacy or security audits and/or to investigate or respond to a complaint or security threat.
In addition, ADMAZES may transfer certain personal information inside and outside of Hong Kong and/or China to companies working with us or on our behalf for the purposes described in this Privacy Statement to the extent permitted by law and subject to the fulfillment of the regulatory requirements of the applicable laws.
ADMAZES may also store personal information inside or outside of Hong Kong and/or China. If we do this your personal information will continue to be protected by means of contracts we have in place with those organisations inside and outside Hong Kong and/or China, which are in a form approved by the competent authority in the applicable jurisdiction.
ADMAZES will not transfer the personal information you provide to any third parties for their own direct marketing use.
2.2 Transfer within the global organisation of ADMAZES firms
To the extent permitted by applicable law, we share information including personal information you provided with other member firms of the ADMAZES global organisation as part of international engagements, and with ADMAZES International and other member firms where required or desirable to meet our legal and regulatory obligations around the world. Other parts of the ADMAZES organisation are also used to provide services to us and you, for example hosting and supporting IT applications, provision of certain forms of insurance for member firms and its clients, performing client conflicts checks and Anti-Money Laundering checks, assisting with client engagement services and otherwise as required in order to continue to run ADMAZES’s business.
By providing ADMAZES with personal information via online systems, visitors are explicitly consenting to this transfer and/or storage of their personal information across borders for the purpose of the foregoing 2.1 and 2.2. If information you provided includes personal information of individuals based within or outside the European Economic Area (“EEA”), you agree to obtain express consent, whenever required under the applicable law, from these individuals prior to the submission of such personal information to ADMAZES.
If information you provided includes personal information of individuals within the People Republic of China, you agree and warrant to notify these individuals of such cross border transfer and obtain separate consent from these individuals, whenever required under the applicable laws, prior to the submission of such personal information to ADMAZES. By consenting to this Privacy Statement, you confirm that explicit consent has been obtained from the relevant individuals.
3. Choices
In general, you are not required to submit any personal information to ADMAZES, but we may require you to provide certain personal information for you to receive additional information about our services and events.
ADMAZES may also ask for your permission for certain uses of your personal information, and you can agree to or decline those uses. If you opt-in for services or communications, such as an e-newsletter, you will be able to unsubscribe at any time by following the instructions included in each communication. If you decide to unsubscribe from a service or communication, we will try to remove your information promptly, although we may require additional information before we can process your request.
As described in “Cookies” above, if you wish to prevent cookies from tracking you as you navigate our sites, you can reset your browser to refuse all cookies or to indicate when a cookie is being sent. Note, however, that some portions of our sites may not work properly if you elect to refuse cookies.
4. Your rights
If you have submitted personal information to ADMAZES, you have the following rights:
· Access and correction: you have the right to access to that data. This is sometimes called a ‘Subject Access Request’. If we agree that we are obliged to provide personal information to you, we will provide it to you free of charge. Before providing personal information to you, we may ask for proof of identity and sufficient information about your interactions with us that we can locate your personal information. If the information we hold about you is incorrect, you may ask us to correct any inaccuracies in the personal information.
· Object to processing: you may have the right to object to us processing your personal information if we are not entitled to use it anymore, to have your information deleted if we are keeping it too long or have its processing restricted in certain circumstances and/or to obtain copies of information we hold about you in electronic form if we are able to do so.
You can make a request or exercise these rights by contacting ADMAZES at info@Admazes.com and we will make all reasonable and practical efforts to comply with your request, so long as it is consistent with applicable law and professional standards.
5. Data security and integrity
ADMAZES has reasonable security policies and procedures in place to protect personal information from unauthorised loss, misuse, alteration, or destruction. Despite ADMAZES’s best efforts, however, security cannot be absolutely guaranteed against all threats. To the best of our ability, access to your personal information is limited to those who have a need to know. Those individuals who have access to the data are required to maintain the confidentiality of such information.
We also make reasonable efforts to retain personal information only for so long as the information is necessary to comply with an individual’s request or until that person asks that the information be deleted and, in any case, no longer than 10 years.
6. Links to other sites
Please be aware that ADMAZES websites may contain links to other sites, including sites maintained by other ADMAZES member firms that are not governed by this Privacy Statement but by other privacy statements that may differ somewhat. We encourage users to review the privacy policy of each website visited before disclosing any personal information.
By registering on any ADMAZES website and then navigating to another ADMAZES website while still logged in, you agree to the use of your personal information in accordance with the privacy statement of the ADMAZES website you are visiting.
7. Changes to this statement
ADMAZES may modify this Privacy Statement from time to time to reflect our current privacy practices. When we make changes to this statement, we will revise the “updated” date at the top of this page. We encourage you to periodically review this Privacy Statement to be informed about how ADMAZES is protecting your information.
8. Policy questions and enforcement
ADMAZES is committed to protecting the online privacy of your personal information. If you have questions or comments about our administration of your personal information, please contact us at info@Admazes.com. You may also use this address to communicate any concerns you may have regarding compliance with our Privacy Policy.
If you are not satisfied with the response you receive, you may escalate your concern to the Firm’s Privacy Liaison by sending an email to: info@Admazes.com
We will acknowledge your email within [14] days and seek to resolve your concern within one month of receipt. Where the concern is complex or we have a large volume of concerns, we will notify you that the concern will take longer than one month to resolve, and we will seek to resolve your concern within three months of the concern being first raised. We may accept your concern (and in that case implement one of the measures set out in the ‘Your Rights’ section above), or we may reject your concern on legitimate grounds.
1 “ADMAZES,” or “we” or “us” refers to ADMAZES Limited, a private English company limited by guarantee, and/or to any one or more of the member firms affiliated with ADMAZES Limited. ADMAZES Limited and its related entities do not provide services to clients.
