1 Pledge
Thelloy Development Group Limited (“TDGL”) pledges to comply with the requirements of the Personal Data (Privacy) Ordinance (Cap. 486) of the Laws of Hong Kong Special Administrative Region.


2 Collection of Information
You may be invited to provide to TDGL your personal data on TDGL’s website(s) or through other media on a voluntary basis for different purposes at different times. If you are under the age of 18, you should obtain consent from your parent or guardian before you provide TDGL with your personal data.


3 Log Files
When you visit TDGL’s website(s), the servers of TDGL will only collect data relating to your visits (including but not limited to your IP address, domain name, browser type and access time) but will not collect your personal data.


4 Use of Cookies
When you browse the website(s) of TDGL, cookies will be stored in your computers, mobile phones 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 functionality of the website(s) of TDGL.


5 Kinds of Information Collected
For the different purposes in the course of conducting TDGL’s business, you may be required to provide to TDGL your personal data, which include your name, gender, e-mail address, mailing address, contact number, membership number, age, marital status, family status, educational level, occupation, username and password, etc. Details of personal data and information to be collected will be set out in the relevant Personal Information Collection Statement (“PICS”) provided to you upon collection of such data and information.


6 Main Purposes and Uses of Information Collected
TDGL will use your personal data for specific purposes identified in the PICS provided to you when your personal data is collected.


7 Accuracy of Information
You may be requested to provide to TDGL certain personal data (particularly relating to your contact information) for specific services. If you fail to provide or update accurate information as requested for each specific service, the provision of such services by TDGL may be affected.


8 Retention of Information
TDGL will retain your personal data for a period no longer than necessary for the fulfillment of the purposes for which they are or are to be used. If you are a subscriber of TDGL services, your personal data will be retained for a reasonable period after termination of your subscription for verification and audit purposes.


9 Third Party Merchants
TDGL may have on-line stores or some services and/or products which are hosted in the website(s) of TDGL but are operated by third party merchants. If you provide your personal data to the third party merchants in order to use, order or receive any services and/or products from the third party merchants, please note that your personal data is beyond the control of TDGL and thus is outside the scope of protection afforded by TDGL.


10 Third Party Websites
The website(s) of TDGL may from time to time contain linkages to other websites. TDGL has no control over your personal data submitted by you, if any, to other websites. This Privacy Policy Statement only applies to the website(s) of TDGL. You should read the respective privacy policies of other websites.


11 Service Providers
TDGL may provide your personal data to the people and companies providing services to TDGL in connection with the specific purposes set out in the PICS (“TDGL Service Providers”). In these cases, the TDGL Service Providers are required to use your personal data consistent with the agreements TDGL enters into with them as well as this Privacy Policy Statement.


12 Security of Information
The physical records of your personal data will be stored in secured places with restricted access. The electronic records of your personal data will be stored in the servers of TDGL located in secured places and protected by adequate IT security measures (e.g. encryption for transmission of sensitive data through the internet in appropriate cases). Only authorized personnel of TDGL (who have been trained to handle your personal data properly and bound by a duty of confidentiality) will have access to these records and servers on a “need-to know” and “need –to-use” basis.


13 Exclusion
TDGL may disclose your personal data as required by law, by any government departments, regulatory authorities, enforcement agencies and courts of competent jurisdiction. TDGL excludes all liability for disclosure of your personal data in this manner.


14 Use in Legal Proceedings etc.
If it becomes necessary for TDGL to take action against you for recovering from you the debt you owe to TDGL, you agree that your personal data can be used by TDGL in identifying and taking legal action against you.


15 Access and Correction of Information and Withdrawal of Consent
You have the right to request in writing to the Personal Data Privacy Officer of TDGL :
a. for access to your personal data held by TDGL (if any);
b. require TDGL to correct your personal data that is inaccurate (if any); and
c. withdraw your consent to the use of your personal data (such withdrawal may, however, affect our services to you).
All such requests will be handled promptly in accordance with the requirements of the Personal Data (Privacy) Ordinance. TDGL may charge a reasonable fee for processing your data access request.


16 Direct Marketing
We cannot use your personal data for direct marketing purposes without your consent. By providing your personal data, you are deemed to have given consent to the use of your personal data as set out in the PICS including for direct marketing. You may withdraw your consent any time by writing to the Personal Data Privacy Officer of TDGL.


17 Change of Privacy Policy
This Privacy Policy Statement may from time to time be updated, revised and changed. Any change, update or modification will be effective immediately upon being posted on website(s) of TDGL. You are advised to check it on a regular basis.


18 Change of Control
If the ownership of certain business of TDGL changes, TDGL may need to transfer your personal data to the new owner of such business so the new owner may continue to operate the business subject to the condition that the new owner shall make use of your personal data in accordance with this Privacy Policy Statement. You will be notified of such transfer and you may decide to withdraw your consent to the use of your personal data.


19 Enquiries
If you have any questions or wish to access or correct your personal data or withdraw your consent to the use of your personal data held by TDGL, please contact the Personal Data Privacy Officer of TDGL at:
Thelloy Development Group Limited
21C, King’s Tower, 111 King Lam Street, Lai Chi Kok, Kowloon
Hong Kong
Personal Data Privacy Officer
(Marked Confidential)


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