Privacy and Data Protection Policy
Introduction
Collection of Personal Data
Purposes for Collection, Use and Disclosure of Your Personal Data
Accuracy and Duration of Retention
Data Security
Exemptions
Contact Us
Introduction
East river Limited ("East river" or "we" or "our" or "us") acts under the Personal Data (Privacy) Ordinance, Chapter 486 of the laws of the Hong Kong SAR. We recognize the importance of the personal data you have provided to us and believe that it is our responsibility to properly manage, protect and process your personal data. Please read this policy to understand what personal data is collected or processed by us, and for what purposes it is used.
Personal data is defined in the Personal Data (Privacy) Ordinance as "personal data
( 個人資料 ) means any data—- relating directly or indirectly to a living individual;
- from which it is practicable for the identity of the individual to be directly or indirectly ascertained; and
- in a form in which access to or processing of the data is practicable;
The purpose of this policy is to inform you and provide you with an understanding of how we handle, collect, use, disclose and process your personal data. Any changes to this Privacy Policy are effective after posting to this website. We recommend you to check this page from time to time to be aware.
By providing your personal data to us, you acknowledge and agree that you have fully read and understood this policy, and consent to the collection, use, processing and disclosure of your personal data as described in this policy.
Your Rights. East river does not claim ownership of the information you submit via the East river Application or through other means of data collection. You have the necessary rights to such information that you submit on the East river Application.
East river’s Rights. We own all copyrights, trademarks, domains, logos, trade dress, trade secrets, patents, and other intellectual property rights associated with our East river Application. You may not use our copyrights, trademarks, domains, logos, trade dress, patents, and other intellectual property rights unless you have our express permission and in accordance with our Terms and Conditions.
Collection of Personal Data
Automatically Collected Information
Usage And Log Information. We collect information about your activity on our East river Application, such as service-related, diagnostic, and performance information. This includes information about your activity (including how you use our East river Application, how you interact with our staff and authorized people in our East river Application, and the time, frequency, and duration of your activities and interactions), log files, and diagnostic, crash, website, and performance logs and reports. This also includes information about when you registered to use our East river Application, your profile photo, whether you are online and when you last used the East river Application.
Device And Connection Information. We collect device and connection-specific information when you install, access, or use our East river Application. This includes information such as the hardware model, operating system information, the app version, browser information, language and time zone, IP, device operations information, and identifiers, for example, the device identifier.
Cookies. Our website and East river Application are set up to automatically collect anonymous information about visitors to help us understand our website visitors and their traffic patterns. This information is used for statistical purposes and to improve our service.
Information you Provide.
Your Personal Data. Examples of such Personal Data you may provide to us include your name, age, birth date, mobile number(s), telephone number(s), mailing or residential address, email address, passport or other identification number, and any other information relating to individuals that you have provided to us during our interaction with you.
Your Messages. We retain the contents of your messages delivered to the East river Application during the course of providing East river services to you. Once your messages (including chats, photos, videos, voice messages, files, and shared location information) are delivered, they are kept and are accessible to East river staff and other government authorities. Your messages are stored on our server. In order to improve our East river Application we store information relating to which country your device indicates you are located in, as well as the device model and operating system you are using. Additionally, your "last login" time and read receipts are visible to East river staff.
We collect your Personal Data in the following ways:
- when you contact our chatbot and/or staff, for example, via chats, emails, telephone/video calls, letters, face-to-face meetings, social media platforms, and our website;
- when you submit forms on our East river Application;
- when you enter information into documents we send to you via our East river Application;
- when you request to be included in our mailing list;
- when you respond to East river advertisements, promotions, initiatives;
- when we receive references from affiliates and third parties, if you have been referred by them;
- when you submit your Personal Data to us for any reason.
Purposes for Collection, Use and Disclosure of Your Personal Data
East river collects, uses and discloses your Personal Data for the following purposes:
- conducting due diligence exercises;
- processing payments;
- replying to your questions, feedback and requests;
- managing East river’s business operations;
- complying with internal policies and procedures;
- providing updates and other communications on the development of East river’s business process and applications;
- assessing and processing applications or requests made by you for East river products and services offered including, but not limited to, corporate secretarial services, incorporation services, tax and accounting services and payroll services;
- managing commercial risks and risk management;
- managing the safety and security of our affiliates and employees;
- managing the safety and security of our premises and services (including but not limited to carrying out CCTV surveillance);
- in connection with any claims, actions or legal proceedings (including but not limited to drafting and reviewing documents, transaction documentation);
- conducting investigations relating to disputes, billing or fraud;
- managing and preparing reports on non-compliance cases;
- meeting or complying with any applicable laws, regulations, codes of practice or guidelines issued by legal or regulatory bodies;
- financial reporting and audit;
- project management;
- requesting feedback or participation in surveys, as well as conducting market research and/or analysis for statistical, profiling or other purposes for us to review, develop and improve the quality of our products and services;
If you have indicated that you consent to receiving marketing or promotional information via your telephone number, emails or other ways of communication, East river may contact you from time to time with information regarding our products and services.
As East river relies on your Personal Data to provide products and services to you, you should ensure that all Personal Data submitted to us is complete, accurate, true and correct.
We will seek your consent and notify you in advance when we collect information for purposes other than listed above or for purposes unrelated to the original purpose when collecting the data, unless with the data subject’s express and voluntary consent. You can withdraw your consent previously given by written notice.
Accuracy and Duration of Retention
East river will retain your Personal Data for only as long as the purposes for which such data is collected or used continues, or where necessary for legal or business purposes.
East river will take all reasonable steps to ensure that all Personal Data is destroyed or permanently deleted if it is no longer required for those purposes.
Data Security
East river will take all practicable steps to protect the Personal Data against unauthorised or accidental access, processing, erasure, loss or use.
Keeping Your Account Secure. You are responsible for keeping your device and your East river account safe and secure, and you must notify us promptly of any unauthorized use or security breach of your account or our East river Application.
Third-party authorization. Our East river application may allow you to invite new users into your chats and company profile to have access, use, or interact with our staff. Users will also be able to view some of your personal information, business data, content, and other products and services. For example, you may invite a new director to your company profile. Please note that when you invite new users into your company profile, we will need to conduct our diligence exercise as per applicable law. Please note East river will not bear any responsibility if your Personal Data is used by unauthorized people that you invited into the East river Application.
Exemptions
Personal Data transferred or disclosed by East river for the purpose of a due diligence exercise conducted in connection with a proposed business transaction is exempted from the provisions (DDP3) of data protection principle (CAP 486 PERSONAL DATA (PRIVACY) ORDINANCE Section 63B Due diligence exercise).
Contact Us
To contact us regarding:
- your Personal Data or our Privacy Policy,
- making a subject access/correction request,
- requesting to withdraw your consent to any use of your Personal Data as set out in this Policy; or
- requesting to obtain access and make corrections to your Personal Data records,
please use the following email address (for the attention of the Data Protection Officer): dpo@osome.com.
If you withdraw your consent to any or all use or disclosure of your Personal Data, depending on the nature of your request, East river may not be able to continue to provide our services or provide access to East river Application. Such withdrawal may also result in the termination of our services.
This privacy policy was last updated on 31 August 2020.
