Notice relating to the Personal Data (Privacy) Ordinance

Notice relating to the Personal Data (Privacy) Ordinance

Kactus Ltd. ("Kactus") is committed to ensuring the privacy and security of the personal data it holds. We aim to meet this commitment by implementing the principles and requirements of the Personal Data (Privacy) Ordinance of the Hong Kong Special Administrative Region ("the Ordinance"). This Privacy Policy Statement is intended to explain our privacy practices.

Collection of Personal Data

"Personal data" refers to any data which directly or indirectly identifies you as an individual, or is capable of doing so. We collect and use personal data that we believe is necessary to conduct our business with you. The types of personal data we collect may include, but is not limited to:

Contact information such as your name, email address, mailing address, telephone number;

Billing information such as your credit card number, bank account information, and billing address;

Demographic information such as age, gender, nationality, marital status, preferences, education background, and employment history;

Supply of personal data to Kactus is non-obligatory, but failure to do so may result in Kactus being unable to process your application or to provide services to you.

Use of Personal Data

Your personal data may be used for the following purposes:

1. Subscription of our product services;

2. For marketing, promotional and customer management purposes, such as sending you offers and promotions (please see further details in "Direct Marketing" below);

3. Facilitating communications between you and Kactus.

We may from time to time also use aggregate non-identifying information about our customers to better design and improve our products and services that we offer. This information will not identify any individual in particular.

Direct Marketing

Kactus intends to use your personal data for direct marketing carried out by Kactus. However, we may not so use or provide your personal data unless exempted by the Ordinance or we have received your consent.

For the above direct marketing use, Kactus intends to:

use your name, contact information and demographic information; and

market or promote our products, services, support, and related events and activities offered or arranged by Kactus.

You can always opt-out free-of-charge by contacting Kactus' Customer Service Officer if you no longer wish any of your personal data to be used in any of the described direct marketing purposes.

Disclosure of Personal Data

Personal data supplied to Kactus will be kept confidential. However, we may disclose such data to or such data may become accessible or known to employees, agents, service providers and consultants of Kactus who provide services to assist in fulfilling the purposes for which it was collected. Your personal data may also be provided to other Kactus’ partners for fulfilling the purposes for which it was collected (subject to any consent requirement relating to "Direct Marketing" above), and to our business partners for direct marketing use as described in "Direct Marketing" above. Other disclosure of your personal data will only be undertaken after we have obtained your prescribed consent, or as may be required by law.

Data Retention

Unless there is a specific legal requirement for us to keep the data, we will take all reasonably practicable steps to erase your personal data that is no longer required for the purposes for which the data was originally collected.

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Commitment to Data Security

Kactus is committed to protecting the security of your personal information. We use a variety of physical, technological and organisational measures to help protect your personal data from unauthorised or accidental access, processing, erasure or other use.

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Changes to the Privacy Policy Statement

We will post on our website at any changes to our Privacy Policy Statement, so that you will always know what information we gather, how we might use that information and whether we disclose it to anyone.

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Access to and Correction of Personal Data

You are entitled to request access to personal data held by Kactus about you and to correct such data. In accordance with the terms of the Ordinance, we may charge a reasonable fee for the processing of such data access requests.

You may direct your request by writing to: