This policy applies to the collection, use, disclosure and protection of Personal Data, relating to customers of HHACO and all of its subsidiaries and related entities ("HHACO "), customers, suppliers of HHACO and website users. This policy has been effective since January 1, 2018.

"Personal Data" 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. "Data Subject" means an individual who is the subject of Personal Data.

Basic Principles

1. HHACO will not collect or maintain Personal Data that is not relevant to or not required for the conduct of HHACO’s business and will take reasonable steps to assure that Personal Data remains accurate.

   Personal Data will be treated as confidential, and sufficient internal procedures and controls will be employed to prevent unauthorized access, disclosure, use, copying, modification and destruction of such Personal Data. Personal Data maintained by HHACO will not be used for purposes that are incompatible with the purposes for which it was collected. Personal Data will not be transferred to any external organization unless we have your consent or are required by law or have previously informed you, and will only be transferred to third parties who have agreed to protect the privacy of Personal Data.

   On-line Registration: If you decide to register with a HHACO web site, you will be asked to provide your personal identification information, for example, your name, company, country, email, and job type. HHACO uses the information that you provide to us during registration to enhance your experience with us. This may include presenting promotional offers to you online or via email (with your consent or in accordance with applicable law). HHACO does this to make your experience with us more pleasant. HHACO uses the Personal Data that HHACO collects about you: to process orders; to help us to improve our site and your online experience; to provide you with information about our products and services; for ordering, customer support, payment, processing and service purposes; to transact business with us; for credit checks, collections and related billing or credit purposes; and as otherwise allowed by law.

   Personal Data Accuracy and Completeness: HHACO aims to maintain Personal Data accurate and relies, in this regards, on its customers, suppliers, and other third parties to give HHACO their Personal Data.

   Updating Personal Data: If you would like to modify or delete the Personal Data held by us on your profile, please send your request to audit@hhaco.com.hk for further assistance.

   Security: Personal Data in HHACO's custody or control is protected by appropriate technology, policies and procedures designed to prevent unauthorized use, access, disclosure, modification, copying or destruction and to maintain the integrity, availability and privacy of Personal Data.

   Opting Out Of Email Communications with HHACO You can choose not to receive emails from HHACO at any time by simply sending an email to us, identifying your name and email address, at audit@hhaco.com.hk and we will remove you from all mailings.

   Emails, Including Special Offers & Site Updates: If you are registered with a HHACO site, HHACO will occasionally send you email about various services and market news update that we feel may be of interest to you and/or about site features and changes that we feel you will want to know about. You can choose not to receive any email from HHACO at any time (see opt out of emails above).

   Cookies: your visit to HHACO sites may be recorded for analysis on the number of visitors to the sites and general usage patterns. Some of this information will be gathered through the use of "cookies", which are small bits of information that are automatically stored on a person's web browser in his computer that can be retrieved by HHACO sites. Cookies can make HHACO sites more useful by storing information about your preferences on particular sites, and therefore enabling us to provide more useful features for our site users. Please note that the information collected by "cookies" is anonymous aggregated research data, and contain no name or address information or any information that will enable anyone to contact you via telephone, email or any other means. You may set our browser to disable cookies or inform you when they are set. However, by disabling cookies, you may not be able to take full advantage of HHACO sites.

   Third Parties: HHACO maintains collaborative relationships with vendors, subcontractors, strategic partners, and others who assist HHACO and our customers in the conduct of our respective businesses. HHACO may from time to time transfer Personal Data to these parties to enable them to work with HHACO, but HHACO requires that they maintain the privacy of Personal Data in a manner satisfactory to HHACO and consistent with applicable law.

2. HHACO will deal fairly with each person whose Personal Data is in HHACO's custody or control.

   Access: You may at any time request for access to, correct and update Personal Data relating to you in any of our records. HHACO will take steps to correct or delete any inaccuracies in Personal Data pointed out to us, either directly or through making available self-service mechanisms. HHACO will endeavor to notify recipients of your Personal Data of such changes where required. However, HHACO may limit access, corrections, or deletions as permitted or required by applicable laws or regulations. HHACO may establish reasonable rules for providing access to Personal Data, including procedures and fees for responding to Access Requests.

   Enforcement: Persons who have questions or believe their Personal Data is not handled in accordance with this Privacy Policy should contact our privacy officer at audit@hhaco.com.hk.

   Legal Requirements

   This Privacy Policy is issued by HHACO in accordance with the Personal Data (Privacy) Ordinance of the Hong Kong Special Administrative Region and applies exclusively to HHACO, its subsidiaries and related entities.

   HHACO may change this Privacy Policy from time to time as it deems appropriate.

   This document describes HHACO’s privacy policy. However, this policy does not grant or create any additional rights or remedies for the Data Subjects or any additional obligations on the part of HHACO other than those obligations required by applicable law.