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PRIVACY POLICY STATEMENT

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The following statement contains Alit Group Limited (hereinafter referred to as “Alit Medical” and also as “we” or “our”) policies and practices with respect to the collection, use, processing, storage, transfer and security of personal data. We are committed to protecting the privacy, security and confidentiality of personal data that we may hold according to the requirements of the Hong Kong Personal Data (Privacy) Ordinance (Cap. 486) and/or laws of any other applicable jurisdiction and shall ensure compliance by our staff members with the standards as prescribed under those laws.   

 

We reserve the right to update and/or modify this statement from time to time, at our sole discretion, without having to provide notice thereof unless we decide to use your personal data for a different purpose than specified at the time of collection. Please read this Privacy Policy Statement carefully and check for updates and/or modifications to this statement on a regular basis. 

 

Collection of Personal Data and Other Data

 

From time to time, we may collect Personal Data from you through the following channels: 

 

  1. our website (www.alitmedical.com) when you register and become a member through our online registration system and/or when you send emails/requests/enquiries to us through our website ‘contact us’ function or through our official social media pages.

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  2.  registration at the exhibits and other events held by us; and

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  3.  surveys and marketing campaigns held by us.

 

Collectively, we refer to our website, social media pages and marketing campaigns together with offline channels (i.e. exhibits) as “the Services”. By using the Services you agree to the Terms.

 

“Personal Data” means any information relating (directly or indirectly) to any living individual from which it is practicable to identify that individual. The type of personal data that we may collect from you may include your name, age, gender, birth date, marital status, e-mail and mailing addresses, country of residence (and other geographical position / location-based information), preferred language, phone and fax numbers, education level, occupation, business information, experience, certifications, username, password, identity card number and tracking information.

 

If you submit any personal data regarding other people for us or our service providers, you shall have the authority and power to do so and you permit us to use the data in accordance with this Privacy Policy Statement. 

 

“Other Data” means any data that does not reveal your specific identity or does not relate to an individual. We may collect other data such as browser and device data (including IP address and data collected through cookies, aggregated data relative to your geographical position and responses to promotional offers (landing pages) and surveys.

 

In some instances, we may combine Personal Data with Other Data. If we do so, we will treat the combined data as personal data as long as it is combined.

 

While you are not obliged to supply your personal data, however, if you do not provide us with the personal data that we request, your application or request may not be processed and/or our services may not be available to you. 

 

How We Collect Personal Data and Other Data

 

We collect personal data by requesting that you complete forms, questionnaires and/or surveys, when you register to Alit Medical’s website, communicate with us through email, social media pages or other means, and when you sign up for our newsletter or participate in our marketing campaigns.

 

When you use or interact with our website and/or Services, we receive, and store information generated by your activity and information automatically collected from your browser or mobile device. For example, like many websites, we obtain certain information when your web browser accesses our website including your IP address, device type, browser type, operating system, sites that were accessed during your visit, pages viewed and access dates. This information helps us to communicate with our customers and enhances our provision of services and products. 

 

We may also collect personal data when you visit Alit Medical’s exhibitions and when you attend promotional events that we host or in which we participate. We further collect personal data when you visit our properties, information may be collected through such properties closed circuit television systems (CCTV) or other security systems.

 

We may store your personal data on our database and may aggregate data that we collect, and this aggregated data will not personally identify you or any other user.

 

Use of Personal Data and Other Data

 

Your personal data may be processed and used by us for the following purposes: -

 

1.  identifying and verifying your identity as well as registering you as a member.

 

2.  processing your applications, orders and requests.

 

3.  providing our information and services to you.

 

4.  communicating with you, including but not limited to responding to your inquiries and sending you invitations and relevant publications.

 

5.  development, management, operation and maintenance of our website, social media pages and business relationship with you.

 

6.  administering and performing customer surveys, marketing campaigns, market analysis, sweepstakes, contests or other promotional activities or events.

 

7.   enforcing the applicable terms of use, establishing or preserving a legal claim or defense, preventing fraud or other illegal activities, solving disputes and enforcing our contractual                           agreements.

 

8.  communicating with you about products, services and projects of Alit Medical we think may be of interest to you and sending you important information regarding our website, changes to our      t.erms, conditions, policies or other administrative issues i.e. by responding to requests or providing you with technical information about purchased products;

 

9.  planning, performing and managing the (contractual) relationship with business partners i.e. by performing transactions and orders of products or services, processing payments, performing          accounting, auditing, billing and collection activities, arranging shipments and deliveries, facilitating repairs and providing support services;

 

10.  maintaining and protecting the security of tour products, services, websites and social media pages, preventing and detecting security threats, fraud or other criminal or malicious activities;

 

11.  ensuring compliance with legal obligations (such as record keep obligations), complying with legal and regulatory requirements or demands in accordance with applicable law, regulations, or        other legal processes including exerting controls.

 

12.  internal business purposes such as developing new products, enhancing our website and social media pages, improving our services, identifying usage trends and visiting patterns,                          determining the effectiveness of our promotions, evaluating third parties performance, predicating our yield and occupancy etc.;

 

13.  performing statistical calculations (some of which may be presented on our website or other services, but such calculations will not include any personally identifiable information or details);

 

14.  any other purposes ancillary or related to the above.

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The legal basis for processing your personal data is made up of one or more of the following reasons:

 

  1. your consent.

 

  2.  providing our products and services.

 

 3compliance with applicable laws, regulations or other legal process.

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  4. legitimate business interests pursued by Alit Medical. 

 

We may also process information contained in or relating to any communication that you send to us (“correspondence data”). The correspondence data may include the communication content and metadata associated with the communication (such as groups, meetings and events). The correspondence data may be processed for the purposes of communicating with you and record-keeping.

 

Disclosure of Personal Data and Other Data

 

We may engage certain agents, contractors and service providers (including Wix.com Ltd and/or other third party IT service providers, marketing and advertisement agents, auditors, advisers, research companies and other services providers for administrative, data processing, digital storage, maintenance, social media and other similar services) in connection with our products, services, business operations and the specified purposes for collecting your personal data, and may disclose, transfer or share your personal data with them, our affiliate companies and relevant members of staff who is responsible for the service and/or matter concerned.  


 

We may also disclose your personal data when required by law or in compliance with a court order of any jurisdiction or as requested by any government or law enforcement authorities or administrative organs or otherwise necessary to establishment of legal claims or defenses, to exercise, defend and protect our rights or property and those of our affiliate companies and to enforce our agreements with you.

 

Unless otherwise provided in this statement or with prior consent, your personal data will not be disclosed to any third party other than the abovenamed parties. 

 

In the event of any reorganization, restructuring, amalgamation, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of Alit Medical business and assets, your personal data may be transferred to the new entity as part of the transaction provided that the new entity abides by this statement and continues to exercise the same level of care and attention in respect of your personal data. In such circumstances, you will be notified and may decide to withdraw your consent to use of your personal data.

 

Cross-Border Transfer

 

As a general principal, data processing is held within European Union (“EU”) and Hong Kong borders including processing by our third parties.

 

Despite the general principal stated above, some information might be held on a cloud server outside Hong Kong or the EU, but we will endeavor to ensure that they will be within jurisdictions listed on the privacy commissioner’s approved ‘white list’. We will ensure that appropriate measures have been put in place to ensure that your personal data is treated with substantially similar level of protection (i.e. the prevailing personal data privacy laws in Hong Kong and through standard contractual clauses of the European Commission, the Internal Company Rules or the Data Protection Shield set up between the European Union and the United States). 

 

We will also ensure that the cloud service provider(s) will keep personal data secure and delete them once no longer needed and comply with the applicable data protection regulations provisions. In event that the recipients to whom Alit Medical transfers your personal data are located in countries in which applicable laws do not offer the same level of data protection, Alit Medical will take reasonable steps to implement appropriate and suitable safeguards for protection of your personal data.

 

Direct Marketing

 

Subject to your consent, we may use your personal data to promote and market products and services to you through direct marketing which may include but not limited to messages and/or notifications to your mobile device, telephone calls, email, facsimile, direct mailing etc. 

 

You can opt-out from receiving such marketing communications at any time and at no charge by notifying us at our contact detail set out herein.

 

Data Retention

 

Alit Medical will only retain your personal data so collected for a period no longer than necessary for an identifiable and ongoing business need, any notified regulatory investigations or active legal proceedings, compliance with any applicable law, regulation, legal process (including without limitation court orders and/or compulsory disclosures required by governmental authorities), fulfilment of legitimate interest of Alit Medical and/or third parties,  fulfilment of the purposes referred to in this statement or as otherwise specified at the time of collection unless otherwise required or permitted by law.

 

Your personal data may be stored in physical locations and/or servers located within or outside Hong Kong. Please rest assured that Alit Medical will take all reasonable steps to ensure that your personal data is stored and processed securely.  

 

Sensitive Data

 

Unless specifically requested, we recommend that you do not send us or disclose to us any sensitive personal data (such as national identification number, data related to racial or ethnic origin, political opinions, religion, ideological or other beliefs, health, biometrics or genetic characteristics, criminal background, trade union membership, administrative or criminal proceedings and/or sanctions).

 

Personal Data of Minors

 

Alit Medical does not knowingly collect personal data from any person under the age of 18.

 

Security

 

We implement reasonable administrative, organizational and technical safeguards and security measures to protect your personal data from authorized access, disclosure, destruction or alteration, accidental loss, misuse or damage. We regularly review and monitor such safeguards and security measures.

 

When disclosure of personal data to third parties is necessary and authorized, we will take reasonable steps to ensure that these third parties undertake the same duty and level of protection, security and confidentiality as offered by us and that the personal data so disclosed are exclusively used and/or processed for the purposes you have accepted.

 

If you have reason to believe that your interaction with us is no longer secure (i.e. if you feel that the security of your account has been compromised), please immediately notify us.

 

Use of Cookies

 

Like many other websites, in order to enhance your experience on our website, some of our webpages may use cookies. By using our website, you consent to the use of these cookies. If you do not agree to the use of these cookies, please disable them by following the instructions for your web browser set out here. Some cookies organizations provide an automated disabling tool in respect of its cookies, see the list of these 3rd party cookies with a link to its automated disabling tool. In other cases, you can disable and control these cookies through 3rd party controls tools like this. Please note that certain features on our website may not work properly if cookies are disabled.  

 

“Cookies” are small data files containing certain information which are placed onto your compute or device when you visit certain parts of our website for record-keeping purposes. Some cookies assist your computer/device to remember certain inputs that you may have placed to make it easier for you to navigate our website. We use cookies to understand website usage/traffic, to improve the content and offerings on our websites, to personalize and better your browsing experience and to make targeted advertisements. However, cookies, by themselves, are not used to collect any personal data unless you choose to provide such information to us.

 

We use session cookies to support the functionality of the website and to understand your use of the website (i.e. which pages you visit, links you use and length of stay on each page etc.). These session cookies are stored only temporarily during a browsing session and are deleted from your computer or device when you close your browser.

 

We may also use Google Analytics (a third-party cookie) to collect and analyze usage of our website. We use the information to compile reports and to help improve our website. These cookies collect information in an anonymous form, for example determining the number of visitors, from where the visitors come to the website and what buttons the visitor clicked. To read Google’s privacy policy in respect of Google Analytics click here, to opt out of Google Analytics click here. Google cookies also include Google AdWords & DoubleClick cookies intended for marketing, advertising and remarketing purposes which recognize visitors on the websites of our advertising partners and to address them interest-related information or advertisements. To find out about Google DoubleClick cookies click here. 

 

For the avoidance of doubt, we are not responsible for the privacy practices of any third-party websites which may be linked to our website or social media pages. We disclaim any liability for any third party’s use of personal data obtained through using such third-party websites. 

 

We may also collect information in relation to your IP address (a numeric code that identifies your computer/device on the internet), browser type and access time for website research and maintenance purposes as well as to gather broad demographic information. 

 

Individuals residing in the EU

 

If you reside in the EU, the following provisions will apply:

 

  1. You have the right to information regarding the processing of your personal data. We would provide you with concise, transparent, understandable and easily accessible information on the conditions for processing your personal data, in clear and simple terms.

 

  2. You are entitled to obtain from us confirmation that your personal data has or has not been processed as well as the conditions of such processing and to receive an electronic copy (for any            additional copy, we are entitled to demand payment of any reasonable fees based on the administrative costs incurred).

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  3. You are also entitled to request from us the rectification of your personal data.

 

  4.  You have the right to receive copy of any personal data which you have provided us with in a structured, commonly used format, and to transmit your personal to another data controller                (where possible and without us hindering it).

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  5. When we process your personal data on the basis of your initial consent, this latter may be withdrawn at any time using the means as provided herein. The withdrawal of your consent is only            valid for future and cannot therefore call into question the lawfulness of the processing carried out before such withdrawal.

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  6.  You have the right to restrict the processing of your personal data in certain circumstances including (i) where you contest the accuracy of your personal data; (ii) where you consider and can            establish that the processing of your personal data is unlawful but you oppose to the deletion of your personal data and demand instead that the processing be limited; (iii) where we no                longer need your personal data but they are still necessary for you to establish, exercise or defend your legal rights; or (iv) where you object to the processing that would be based on the              legitimate interest of the controller, during the verification whether the legitimate grounds pursued by the controller prevail over those of the person in question.

 

  7.  Subject to the exceptions provided by applicable law, you have the right to request the erasure of your personal data in certain circumstances including (i) where your personal data is no                 longer necessary for the purposes for which they were collected or otherwise processed; (ii) where you wish to withdraw your consent on which the processing of your personal data was                 based  and there is no other basis justifying such processing; (iii) where you can prove that your personal data has been unlawfully processed; or (iv) where your personal data must be erased        accordance with a legal obligation.

 

 8.  You have the right to organize the fate of your personal post-mortem data through the adoption of general or specific guidelines. We are committed to respecting these guidelines. In the              absence of directives, we recognize the possibility for heirs to exercise certain rights, in particular the right of access, if it is necessary for the settlement of the deceased’s estate the right to            object to the closure of the deceased’s user accounts, and the right to object to the processing of their data.

 

 9.  You have a right to lodge a complaint with a supervisory authority if you feel that any of your rights have been infringed by us. A list of control authorities is available on the European                       Commission’s website.

 

 10.  If you reside anywhere outside the EU (such as Hong Kong) your rights to review, edit or amend personal data held in our databases will be governed by applicable Hong Kong laws                         including the provisions of the Hong Kong Personal Data (Privacy) Ordinance (Cap. 486) or the laws of any other applicable jurisdiction. 

 

Access and Correction of Personal Data 

 

You are entitled to request access to, receive copy of and correct, update or erase of your personal data at any time. You may do so by sending your request or any questions that you may have about this Privacy Policy Statement in writing to:

 

Data Protection Officer

Alit Group Limited

Room 1101, Kai Wong Commercial Building

222 Queen’s Road Central, Hong Kong

Telephone: 9811 8857

Email: info@alitmedical.com

 

Last updated on: November 02nd, 2020

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