Personal Data Privacy and Personal Information Collection Statement

This Statement applies to K-Gold International HongKong Limited (referred to as “K-Gold” or “The Company”).
In this Statement, the term “data subjects”, “you” or “customer” shall include visitors to the Company’s website, users of K-Gold’s services and customers. In addition, in this statement, the term “group company” refers to the Company’s local and overseas group companies (such as parent companies or subsidiaries of the same holding).
The content of this Statement shall apply to all data subjects and form part of the terms and conditions of any agreement or arrangement that the data subjects have or may enter into with K-Gold from time to time. In the event of any inconsistency or discrepancy between this Statement and the relevant agreement or arrangement, this Statement shall prevail insofar as it relates to the protection of the data subject’s personal data.

Privacy Policy Statement

1. The Company’s privacy policy and commitment

K-Gold values your privacy. K-Gold is committed to ensuring our staff to follow and implement the Personal Data (Privacy) Ordinance (Cap. 486, Laws of Hong Kong) (the “Ordinance”) in order to fully protect the privacy of your data from leaking. This Statement is intended to assist you in understanding K-Gold’s privacy policies and practices in relation to personal data.

2. Collection of Personal Data

Personal data means any information relating to an individual from which the identity of the individual can be ascertained, directly or indirectly. We may collect the following data relating to you, which may become personal data from time to time, including but not limited to:

1. (1) Name
2. (2) Age
3. (3) Gender
4. (4) Phone number and service provider
5. (5) Email address
6. (6) HKID number or passport number
7. (7) nationality or residency status;
8. (8) Birth date
9. (9) Personal financial status
10. (10) Income or assets information
11. (11) Education level
12. (12) Employment information
13. (13) Residential information
14. (14) Bank account or stored value facility account details
15. (15) Personal preference related to any products or services
16. (16) Communication between you and K-Gold
17. (17) Data regarding your visits to and use of K-Gold website and K-Gold LiveChat; and
18. (18) Information about your browsing and use of the K-Gold website

3. Purpose of collecting personal data

1. (1) In order to enable K-Gold to provide better services, it is necessary from time to time for customer to provide K-Gold with personal data when opening or continuing membership accounts, establishing or continuing or receiving other services from us.
2. (2) Failure to supply such personal data may result in K-Gold being unable to open or continue membership accounts, or to establish or continue or to provide other services to customers.
3. (3) In the normal course of business, for example, customers communicate with K-Gold verbally or in writing (including but not limited to e-mail, postal mail) , K-Gold will also collect personal data from customers through electronic records or telephone recordings (depending on situation) .
4. (4) In order to enable K-Gold to provide better services, subject to consent of customers, personal data of customers may be obtained from credit reference agency (whose contact details can be provided upon request). K-Gold may also obtain personal data through different channels, such as public registers, public search engines, public directories or any social media in the public domain with settings authorized for public viewing by customers. In addition, device information may be collected from data subjects’ web browsers.
5. (5) The personal data of data subjects may be used by K-Gold for the following purposes:
   1. (a) processing and approving applications for services or purchase of products and daily operation related to providing services and products to customers;
   2. (b) creating and maintaining the K-Gold’s internal scoring or risk related models;
   3. (c) ensuring ongoing credit worthiness and good standing of data subjects;
   4. (d) designing and developing new products and services for data subjects’ use;
   5. (e) conducting marketing research or internal study for providing better services;
   6. (f) subject to the consent of data subjects, direct marketing services, marketing products, services and related matters as described in paragraph 9 below;
   7. (g) determining the amounts of indebtedness owed by data subjects to K-Gold;
   8. (h) exercising the Company’s rights under contracts with data subjects including collecting amounts outstanding from data subjects;
   9. (i) ensuring K-Gold and any company within the Group Company to implement and comply with such obligations, regulations or arrangements related to the disclosure or use of data:
   10. (i) any law, regulation, judgment, court order, voluntary code, sanctions regime applicable to the Company or Group Company, issued within or outside the Hong Kong Special Administrative Region (HKSAR) existing currently or in the future.
   11. (ii) any guidelines, guidance, rules or codes of practice or requests given, published or issued by any law, regulatory, governmental, tax, law enforcement or other authorities, relevant stock exchange, self-regulatory or industrial bodies or associations of financial service providers within or outside HKSAR existing currently or in the future.
   12. (iii) any present or future contractual or other commitment with local or foreign legal, regulatory, governmental, tax, law enforcement or other authorities, or self-regulatory or industry bodies or associations of financial services providers that is assumed by or imposed on K-Gold or any Group Company by reason of its financial, commercial, business or other interests or activities in or related to the jurisdiction or the relevant local or foreign legal, regulator, governmental, tax, law enforcement or other authority, or self-regulatory or industry bodies or associations;
   13. (j) complying with any obligations, requirements, policies, procedures, measures or arrangements of K-Gold or Group Company for the use of data and information in accordance with sanctions or prevention or detection of money laundering, terrorist financing or other unlawful activities;
   14. (k) maintaining a transaction history or otherwise, a record of data subjects (whether or not there exists any relationship between data subjects and the Company) for present and future reference; and
   15. (l) managing, upgrading maintaining or providing K-Gold LiveChat and processing or responding to any data subjects’ enquiries or requests through K-Gold LiveChat.
   16. (m) any other purposes relating to the purposes listed above.

4. Categories of possible transferees of personal data

All personal data held by K-Gold will be kept confidential but K-Gold may disclose or transfer such information to the following parties for the purposes set out in paragraph 3 above:

1. (1) any service provider who, for the purpose of facilities, establishment, operation, maintenance or provision of services, provides administrative, mailing, telecommunications, telemarketing, direct selling agent, data services, computer, payment, data processing, professional, consulting debt collection or other dealings with K-Gold or any entity within the group of companies (including its employees, officers, agents, contractors, service providers, professional advisors or third-party service providers);
2. (2) any other person who is under a duty of confidentiality to K-Gold and has undertaken to keep such information confidential
3. (3) Any person to whom K-Gold is obliged or otherwise required to make “Relevant Disclosure”; and “Relevant Disclosure” means: a disclosure under any law binding or applicable to K-Gold; or by any government , legal, law enforcement, regulatory, tax or other authority, or financial services provider’s self-regulatory or industry body or organization made or promulgated by K-Gold is expected to comply with any guidance or guidance and any disclosures to which it refers; or any disclosure pursuant to any contractual commitments or other commitments between K-Gold and local or foreign legal, regulatory, governmental, tax, law enforcement or other authorities, or financial service providers’ self-regulatory or industry bodies or organisations (the above may be are currently or in the future in force within or outside Hong Kong);
4. (4) any entities within the Group Company of K-Gold
5. (5) Personal data collected in Hong Kong by K-Gold may be transferred to a place inside or outside Hong Kong.

5. Security of personal data

The policy of K-Gold is to ensure sufficient protection to personal data and to fully comply with the requirements under the Ordinance (especially Data Protection Principle 4 under the Ordinance) based on the degree of sensitivity of the data and damage arising from unauthorized access. To prevent data from being accessed, processed or used for other purposes without authorization , K-Gold is used to provide secured data storage to limit the access of physical contact. K-Gold also takes steps to ensure that persons accessing such information are of good conduct, prudence and competence. Information will only be transmitted in a secure manner.

6. Accuracy of personal data

K-Gold’s policy is to ensure that all personal data collected and processed by K-Gold is accurate and fully complies with the requirements under the Ordinance (in particular Data Protection Principle 2 under the Ordinance). K-Gold implements appropriate procedures to regularly check and update all personal data to ensure that the data is accurate for the purpose for which it is or will be used. If personal data held by K-Gold contains a statement of opinion, K-Gold will take all reasonably practicable steps to ensure that any facts quoted in support of the statement of opinion are correct.

7. Collection of personal data

1. (1) In the course of collecting personal data, K-Gold will provide the individuals concerned with a link to the “Personal Data Collection Statement” before the data subjects submit the membership application form, informing them of the purpose of collection, classes of persons to whom the data may be transferred, their rights to access and correct the data and other relevant information.
2. (2) In relation to the collection of personal data by online, the following practices are adopted by the Company:

   (a) Online security

   The Company will follow strict standards of security and confidentiality to protect any information provided to the Company online. Encryption technology is employed for sensitive data transmission on the Internet to protect individuals’ privacy.

   (b) “Cookies”

   “Cookies” are designed to be read only by the sending website, but cannot be used to obtain a user’s hard drive data, email address or to collect sensitive information of user . Small data files are placed on data subject’s device when data subject visits the Company’s website or clicks on the Company’s online advertisement such that the web server can later read back the cookie data from a web browser. This is useful for allowing a website to maintain information on a particular user.「Cookies」or similar technique applied to the purposes below :

   1. (i) K-Gold only uses “Cookies” to identify users in a specific period, and does not store sensitive information of users in “Cookies”. When users browse the K-Gold website, all contacts will use “Cookies” to identify users.
   2. (ii) statistical analysis of your on-site behavior such as number of visits to our site, page views, length of time spent on each page. These are aggregated and therefore anonymous.
   3. (iii) In order to improve the user experience, remember your preferences when using the K-Gold website so that you can easily navigate both the public and member part ; and
   4. (iv) Use of pages visited by the data subject and links to websites opened to promote personalized products:
      • make K-Gold’s website more relevant to the interests of you;
      • provide online advertisements on K-Gold’s website or third-party websites that are most likely to interest you ; and
      • evaluate the effectiveness of K-Gold’s online marketing and advertising programs.

      The above cookies may be placed on data subject’s device by K-Gold or by third parties on K-Gold’s behalf (for example, advertising networks and providers of external services like web traffic analysis services). Information recorded through the use of cookies by third parties are aggregated and then shared with K-Gold as anonymous aggregated research data. No personal contact information about data subjects is collected or shared by third parties with the Company as a result of the use of cookies. The cookies will expire once the session is closed.
      Most web browsers are initially set up to accept cookies. Should you wish not to be tracked by this kind of technology, you can choose ‘not accept’ cookies by changing the settings on your web browser. However, if you block all cookies, including strictly necessary cookies, you may not be able to use K-Gold’s website and K-Gold LiveChat properly.

   5. (v) Data correction online
      Personal data may not be changed, deleted or updated once summited online .If user cannot change , delete or update data online , you should call K-Gold.
   6. (vi) Online retention of information
      Personal data collected online will be sent to related department. Personal data will not store in K-Gold website’s server normally.

8. Data retention

K-Gold will take all practical measures to ensure that personal data is not kept longer than is necessary to carry out the purpose for which the data is or is to be used (including any directly related purposes) .

9. Direct marketing

K-Gold intends to use a data subject’s data to conduct direct marketing of products or services (on a voluntary basis) provided that K-Gold and entities in group company shall not use the personal data of the data subject for this purpose without obtaining the data subject’s prior consent (which includes an indication of no objection).In this connection, please note that:

1. (1) the name, contact details, loan products and other service portfolio information, transaction pattern and behavior, financial background and demographic data of data subject held by K-Gold from time to time may be internally transferred and used by K-Gold in direct marketing;
2. (2) the following classes of services, products and subjects to be used in direct marketing:
   (a) luxury products (e.g. handbag, watch, jewelry) related services and products; and rewards, loyalty or privilege programs and related services and products.
3. (3) K-Gold would like to use personal data of data subjects for direct marketing purpose any purpose for direct marketing is entirely voluntary. According to the definition given by the Office of Privacy Commissioner for Personal Data, Hong Kong, the definition of “consent” also includes “an indication of no objection”. If data subjects do not wish K-Gold to use or provide to other persons their personal data for direct marketing as described above, or wish K-Gold to advise other persons to stop using their personal data for such direct marketing purpose, they may notify us of the same at any other time, without charge.

For the avoidance of doubt, K-Gold will not use personal data of third parties for direct marketing purposes unless they have given their express consent.

10. Access and Correction of Personal Data

1. (1) Under and in accordance with the terms of the Ordinance and the Code of Practice on Consumer Credit Data (the “Code”), you have the right:
   1. (a) to check whether K-Gold holds personal data about you and to access such data.
   2. (b) to require K-Gold to correct any personal data relating to you which is inaccurate;
   3. (c) to ascertain K-Gold’s policies and practices in relation to personal data and to be informed of the kind of personal data held by K-Gold;
   4. (d) in relation to consumer credit data, to be informed, upon request, which items of personal data are routinely disclosed to credit reference agencies or debt collection agencies and be provided with further information to enable the making of an access and correction request to the relevant credit reference agency or debt collection agency; and
   5. (e) in relation to consumer credit data, upon termination of your account by full repayment and on condition that there has not been, within 5 years immediately before account termination, any material default on your account, to instruct K-Gold to make a request to the credit reference agency to delete from its database any account data relating to your terminated account.
2. (2) In accordance with the terms of the Ordinance, K-Gold has the right to charge a reasonable fee for the processing of any data access request.
3. (3) You should send any requests for access to personal data or correction of personal data or for information regarding our policies and practices to:
   

   Address	:	Unit 906, 9/F, Office Plus @ Prince Edward, 794-802 Nathan Road, Prince Edward, Kowloon
   Email	:	info@k-gold-hk.com

4. (4) Nothing in this Privacy Policy and Personal Information Collection Statement shall limit the rights of the data subjects under the Ordinance.

Effective Date: April 2023