PRIVACY POLICY STATEMENT AND PERSONAL INFORMATION COLLECTION STATEMENT

1. Introduction

This Privacy Policy Statement and Personal Information Collection Statement (the “Privacy Policy”) aims to give you information on how Hop Hing Oil Group Limited (the “Company”) and its affiliates (collectively as “we”, “us” or “our”) collect and process your personal data.

We respect your privacy and are committed to protecting your personal data. This Privacy Policy describes how we collect, use and disclose your personal data, and what rights you are entitled to with respect to the use of your personal data.

2. Purpose of this Privacy Policy

In line with our obligations under, where necessary and appropriate, the Personal Data (Privacy) Ordinance (Chapter 486 of the Laws of Hong Kong) (the “PDPO”) and other applicable privacy laws, this privacy policy sets out how we will collect, hold and use your personal data. In particular, the table in the section “Why we Use Your Personal Data” below specifies the purposes for using your personal data as a data user.

3. Types of Personal Data Collected

According to the PDPO, personal data means information which relates to an individual and can be used to identify that individual. It must also exist in a form which access to or processing of is practicable.

For the purpose of carrying on our business, including registration and administration of our website for related products and services (including relevant online services), we will collect, use, store and transfer different kinds of personal data which we have grouped together as follows:

Identity Data* includes first name, last name, username or similar identifier, marital status, title, date of birth and gender.
Contact Data* includes billing address, delivery address, email address and telephone numbers.
Financial Data* includes bank account and payment card details.
Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
Technical Data includes internet protocol (IP) address, login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
Profile Data includes username and password, purchases or orders made, your interests, preferences, feedback and survey responses, education and profession, hobbies and leisure activities, other related products and services subscribed to, and family and household demographics.
Usage Data includes information about how you use our website, products and services.
Marketing and Communications Data includes your preferences in receiving marketing materials and your communication preferences.

Please note that in the course of providing our products or services pursuant to your order, or as required by law, we may specify that it is mandatory for you to provide certain personal data including those specified above marked with asterisks, while we may also request your provision of certain personal data on an optional basis. In the event that you do not provide the personal data which we specify to be mandatory, we may not be able to process the order. In this case, we may cancel the order and will notify you as soon as possible.

4. How is Your Personal Data Collected?

We use different methods to collect data from and about you through:

Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by contacting with us by post, phone, email or otherwise. This includes personal data you provide when you:
- place an order for our products or services;
- subscribe to our services or publications;
- request our marketing materials;
- participate in a competition, promotion or survey; or
- give us some feedback.
Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. You may adjust your preference regarding cookies in your browser settings.
Third parties or publicly available sources. We may receive personal data about you from various third parties as set out below:
- Technical Data from the following parties:
  - analytics providers such as Google Analytics;
  - advertising networks such as Google Ads; and
  - search information providers such as Google, Bing, Yahoo.
- Contact, Financial and Transaction Data from providers of technical, payment and delivery services.
- Identity and Contact Data from data brokers or aggregators.
- Identity and Contact Data from publicly available sources.
Where we are a data user in respect of your personal data, we are required by PDPO to be clear about the purposes for which we are processing that personal data and our lawful basis for doing so.

5. Why We Use Your Personal Data

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Purpose/Activity	Type of data	Lawful basis for processing including basis of legitimate interest
To register you as a new customer	Identity Contact	Performance of a contract with you
To process and deliver your order including: Manage payments, fees and charges Collect and recover money owed to us	Identity Contact Financial Transaction Marketing and Communication	Performance of a contract with you Necessary for our legitimate interests (to recover debts due to us)
To manage our relationship with you which will include: Notifying you about changes to our terms or privacy policy Inviting you to leave a review or take a survey	Identity Contact Profile Marketing and Communication	Performance of a contract with you Necessary to comply with a legal obligation Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
To enable you to participate in a prize draw, competition or complete a survey	Identity Contact Profile Usage Marketing and Communication	Performance of a contract with you Necessary for our legitimate interests (to study how customers use our products/services, and to develop them and grow our business)
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)	Identity Contact Technical	Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, preventing fraud and in the context of a business reorganisation or group restructuring exercise) Necessary to comply with a legal obligation
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you	Identity Contact Profile Usage Marketing and Communication Technical	Necessary for our legitimate interests (to study how customers use our products/services, to develop and grow our business and to inform our marketing strategy)
To use data analytics to improve our website, products/services, marketing, and customer relationships and experiences	Technical Usage	Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
To make suggestions and recommendations to you about goods or services that may be of interest to you	Identity Contact Technical Usage Profile	Necessary for our legitimate interests (to develop our products/services and grow our business)

6. Marketing by Us and Third Parties

We would like to provide you with choices regarding certain uses of personal data, particularly in relation to marketing and advertising.

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you. However, we shall not use such Data unless we receive your prior consent for such use or an indication of no objection.

Upon your consent or indication of no objection, you will receive direct marketing communications from us where you have purchased products or services from us as an individual customer or if you have requested information from us and, in each case, you have not opted out of receiving those marketing materials.

Your consent or indication of no objection to receive direct marketing communications can be withdrawn anytime by unsubscribing from each email sent to you as part of a campaign and by making a request to unsubscribe on the “Contact Us” page on our official website (www.hophing-oil.com).

7. Retention of Personal Data

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, and the purposes for which we process your personal data and whether we can achieve those purposes through other means and the applicable legal requirements.

In some circumstances, you can ask us to delete your personal data: see under Your Data Protection Rights for further information.

In some circumstances, we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

8. Disclosure and/or Transfer of Personal Data

We may share your personal data with and/or transfer your personal data to the parties set out below to enable us to carry out the activities specified in the table above:

Any subsidiaries, holding companies, associated companies, or affiliates of, or companies controlled by, or under common control within the Company;
Any person or company who is acting for or on behalf of the Company, or jointly with the Company, such as our service providers including hosting providers, advertising and email service provider; and
Any party as ordered by court or competent authority. For example, if we were served with a court order demanding certain customer information and then we would need to disclose the information to the duly appointed officer of the court or such other persons as the court orders.

In addition, if we choose to sell, transfer, or merge parts of our business or our assets or if we seek to acquire other businesses or merge with them, we may need to share your personal data with those other businesses. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.

We require all third parties to respect the security of your personal data and to treat it in accordance with the relevant laws and regulations. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes in accordance with our instructions.

9. Storage of Your Personal Data

Personal data may be stored on our servers and/or servers which are only accessible and controllable by us located in different international jurisdictions and be processed outside Hong Kong Area.

Whenever we transfer your personal data out of Hong Kong, we will ensure that a similar degree of protection is afforded to it.

10. Security of Personal Data

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have business relationship with us and need to know the information. They will only process your personal data according to our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

11. Your Data Protection Rights

Under certain circumstances, you have rights under the PDPO in relation to your personal data. This may include the following rights:

Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have exercised your right to object to processing (see below).
Object to processing of your personal data. This right applies where we are relying on our legitimate interests (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal data for direct marketing purposes.
Request the restriction of processing of your personal data. This enables you to ask us to suspend the processing of personal data about you, for example, if you want us to establish its accuracy or the reason for processing it.
Request the transfer of your personal data to another party (known as the “right to data portability”).
Withdraw consent. This right applies only if we are relying on your consent to process any of your personal data. This will not affect the lawfulness of any processing carried out before you withdraw your consent.

If you wish to exercise any of the rights set out above, please contact hho@hophing-oil.com.

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

We try to respond to all legitimate requests within one month. Occasionally, it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated of the status.

12. Changes to this Privacy Policy

We reserve the right to modify this Privacy Policy from time to time. If we make changes to this Privacy Policy, the updated Privacy Policy will be posted on our webpage in a timely manner and, if we make material changes, we will provide a prominent notice.

This Privacy Policy was written in English. To the extent a translated version conflicts with this Privacy Policy, the English version shall prevail.

13. Getting in Touch

If you have any questions about this Privacy Policy, including any requests to exercise your legal rights under the PDPO, please contact our data protection officer through the following means:

E-mail:	hho@hophing-oil.com
Telephone:	(852) 2943 7810
Mailing Address:	Units E – F, Hop Hing Building, 9 Ping Tong Street East, Tong Yan San Tsuen, Yuen Long, New Territories, Hong Kong

(Effective from 1^st September 2023)