Privacy Policy

1. General Statement

1. This notice on Personal Data Privacy Policy will inform you as user of the website as to how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you. Specifically, this notice is given to users of our website pursuant to the Personal Data (Privacy) Ordinance (Cap. 486 of the Laws of Hong Kong) (“Ordinance”) in relation to the collection and processing of Personal Data (defined hereinafter) by the Company for the Company’s business activities and its compliance with applicable laws, guidelines or requested by regulatory or other authorities including the Privacy Commissioner for Personal Data of Hong Kong and The Financial Action Task Force.
2. The Company's Personal Data Privacy Policy (the “Policy”) specifically addresses the Company’s obligation in respect of the applicable data privacy laws and in certain circumstances, the Company is under the obligation to disclose such Personal Data to the regulated authorities.
3. This website is not intended for children and we do not knowingly collect data relating to children It is important that you read this notice together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. For the processing of the personal data of a child below the age of 18, the consent of the holder of guardian is necessary. We shall make reasonable efforts to verify in such a case that consent is given or authorized that way, taking into consideration available technology. This privacy policy supplements other notices and privacy policies and is not intended to override them.
4. The Company may make changes to this notice from time to time. Any changes will be posted on the website of the Company.

2. Personal Data

1. In the Ordinance, “Personal Data” is defined as “any recorded information relating to a living individual from which his/her identity can be directly or indirectly ascertained”. 

   For the purpose of compliance with applicable laws, guidelines or requested by regulatory or other authorities in and outside Hong Kong, you may be requested by the Company to provide Personal Data such as, but not limited to, the following:-

   • name;
   • telephone number, fax number and e-mail address;
   • occupations and title; and
   • other information stated in Clause 2.2 below.

2. Specifically, your use of the website, signing-up and joining in to our membership, participation of seminars and/or other events, subscription of newsletters or purchasing products or services, the Company may collect, use, store and transfer your Personal Data  which the Company has grouped together as follows:

   • information you provide by completing the enquiry form (a direct interaction with the website) on the website which includes name, email address, contact details if given (“Contact Data”) and the nature of enquiry (“Transaction Data”);
   • further information regarding specific enquiry to help the Company fully understand the enquiry and deal effectively; and
   • details of visits to the website using automated techniques or interactions including, but not limited to, traffic data (which may be provided by an analytics provider), location data, weblogs and other communication data (“Usage and Technical Data”).

   The Company does not collect any Special Categories of Personal Data about you (this includes details about race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about health, and genetic and biometric data). Nor the Company do collect any information about criminal convictions and offences.

3. Purposes of Collection

1. The Personal Data provided from you to the Company and in any documentation, which comes into existence as a result of the business relationship with the Company, will be used by the Company for the following purposes:-

   • maintaining of membership, keeping you informed about lectures, seminars, recruitment and/or business activities relating to reagents for research provided by the Company, to respond to your query, to help improve products and services, including for the purposes of research, feedback and enquiries;
   • marketing and advertising of any goods and/or services to you by the Company;
   • where the Company needs to perform the contract, or the Company is about to enter into or have entered into with you;
   • where it is necessary for legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests;
   • maintenance of particulars and Personal Data in compliance with the applicable ordinances and subsidiary legislation which are enacted and effective in Hong Kong relating to the business activities of the Company and also in compliance with the applicable laws, rules and regulations to the Company and other regulatory and authorities in Hong Kong and overseas; and/or
   • any other purposes as you and the Company separately agreed from time to time.

4. Your Obligation to provide Personal Data

1. When providing any Personal Data to the Company, please ensure that the Personal Data is accurate and updated by having regard to your obligations under the Ordinance.

5. Controller, Retention and Security of Personal Data

1. Subject to Clause 7 below, all Personal Data collected and held by the Company as controller of Personal Data will be kept confidential and the Company retains your Personal Data for as long as is necessary to fulfil the original or directly related purpose for which they were collected.
2. The Personal Data are securely stored and access to the Personal Data without appropriate authorisation are strictly prohibited and authorisation are granted only on a “need to know” basis and will be accredited to upon appropriate training.
3. The Company will only retain the Personal Data for as long as reasonably necessary to fulfil the purposes be collected for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements.  The Company may retain Personal Data for a longer period in the event of a complaint or if the Company reasonably believes there is a prospect of litigation in respect to the relationship with you. To determine the appropriate retention period for Personal Data, the Company considers the amount, nature and sensitivity of the Personal Data, the potential risk of harm from unauthorised use or disclosure of Personal Data, the purposes for which the Company processes Personal Data and whether the Company can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

6. Accuracy of Personal Data

1. The Company according to the need may validate the Personal Data provided by you. Please keep us informed if your Personal Data changes during your relationship with the Company.

7. Provision, Sharing, Disclosure of Information

1. The Company does need to share Personal Data with some third parties in some circumstances, for example:- (a) in the event the Company needs guidance or third party advice to respond to your specific enquiry (b) if the Company is under a duty to comply with any legal or regulatory obligation (c) in order to enforce or apply our terms of use or other agreements; or to protect the rights, property, or safety of the Company, its customers or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction. The Company requires all third parties to respect the security of Personal Data and to treat it in accordance with the law. The Company does not allow any third-party service provider to use Personal Data for their own purposes and only permit them to process Personal Data for specified purposes and in accordance with our instructions.
2. The Company may, as it deems necessary, disclose to its agents or nominees, subsidiaries, holding companies, related companies, associates, affiliates, subcontractors or individuals, and the Company's auditors and legal and/or other advisers who is under a duty of confidentiality to the Company, such information as is required to provide its services relating to the activities described in Clause 3.1 above.  For the avoidance of doubt, you provide your consent to the Company for its transfer of any of the Personal Data provided herein to any party to whom it is authorised to disclose the same pursuant to this Clause 7 notwithstanding that such party's principal place of business is outside of the country of residence or that such Personal Data following disclosure will be collected, held, processed or used by such party in whole or part outside of the country of residence or the transfer is otherwise made to a person outside of Hong Kong.
3. In compliance with any statute and subsidiary legislation which are enacted and effective in Hong Kong and also in compliance with the applicable laws, rules and regulations, the Personal Data provided by you may be disclosed to government bodies, other regulatory authorities, individuals or corporations who have the right to such Personal Data and information as prescribed by applicable law and, in addition to the foregoing, any relevant government, supervisory or regulatory authority or court of law to which the Company's agents or nominees, subsidiaries, holding companies, related companies, associates, affiliates, subcontractor, individuals or corporations (who are entitled pursuant to this notice to receive Personal Data relating to you) are subject.

8. Request for Access, Correction and Deletion of Personal Data

1. The Company fully complies with the “Right of Access and Correction” obligations of the Ordinance. In accordance with the terms of the Ordinance, you may request access to the Personal Data supplied by you to ascertain whether the Company hold any personal Data and, if so, obtain such Personal Data and may request the Company to correct any inaccurate Personal Data for the purpose for which it is being used.
2. You can ask the Company to Delete or Remove Personal Data where there is no good reason for the Company continuing to process it. You also have the right to ask the Company to delete or remove Personal Data where you have successfully exercised the right to object to processing (see below), where the Company may have processed your information unlawfully or where the Company is required to erase Personal Data to comply with local law. Note, however, that the Company may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of the request.
3. Where the Company is relying on a legitimate interest (or those of a third party) and there is something about situation which makes you want to Object to Processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where the Company is processing Personal Data for direct marketing purposes. In some cases, the Company may demonstrate that the Company has compelling legitimate grounds to process the information which override rights and freedoms of you.
4. You can ask the Company to Suspend the processing of Personal Data in the following scenarios:
   • if you want the Company to establish the data's accuracy;
   • where the use of the data by the Company is unlawful but you do not want the Company to erase it;
   • where you need the Company to hold Personal Data even if the Company no longer requires it as you need it to establish, exercise or defend legal claims; and/or
   • you have Objected to the Company’s use of Personal Data but the Company needs to verify whether the Company has overriding legitimate grounds to use it.

5. You have the right to withdraw consent at any time by contacting the Company where the Company is relying on consent to process your Personal Data. However, this will not affect the lawfulness of any processing carried out before you withdraw the consent. If you withdraw the consent, the Company may not be able to provide certain products or services to you. The Company will advise you if this is the case at the time you withdraw the consent.

6. You also have the right to ascertain the Company’s policies and practice in relation to the Personal Data.

7. The Company will, upon satisfying itself of the authenticity and validity of the access request from you, make every endeavour to comply with and respond to the request within the period set by the Ordinance (i.e. within 30 days after receiving the request).

9. Direct Marketing

1. The Company may use your Personal Data in direct marketing to provide you with marketing information such as events, activities, promotions and offers provided by the Company.
2. The Company intends to use the following Personal Data in such direct marketing:-
   • name;
   • telephone number, fax number and e-mail address.
3. The Company will not provide your Personal Data to third parties for their use in direct marketing unless the Company has received your written consent.

10. Cookies

1. The Company’s website uses cookies and stores information on how you use the website. The information is anonymous and will not be linked back to you as an individual. You can reject and block cookies in browser settings.

11. Enquiries

1. Enquiries concerning the Personal Data provided by you to the Company, including the request for access, corrections, removal and object or suspension of processing should be addressed to:-

   Attention to the Managing Director

   ROHTO Advanced Research Hong Kong Limited

   Units 312-313, Building 15W,
   No. 15 Science Park, West Avenue,
   Pak Shek Kok, Hong Kong Science Park,
   Hong Kong

   Telephone:	+852 3845 3600
   Email:	research@arhk.rohto.com
   Fax :	+852 3621 0311

   
   

   The Company will respond as soon as reasonably practicable and in any event within 1 month (i.e.40 days under Hong Kong laws) of such a request.

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