Privacy Policy Statement
Please note that this statement may be revised from time to time without prior notice. You should review the latest version periodically.

StartupCow Business Solutions Limited (hereinafter referred to as “StartupCow”) is committed to complying with the responsibilities and requirements of the Personal Data (Privacy) Ordinance (hereinafter referred to as the “Ordinance”). Our employees are also required to keep confidential all personal data collected, stored, and/or used by StartupCow, and we strive to properly safeguard such data and adhere to the responsibilities and requirements stipulated by the Ordinance.

Purposes and Methods of Personal Data Collection
The purposes and methods for which StartupCow collects personal data include, but are not limited to, the following:

• When using or browsing the StartupCow website;
• When using services provided by StartupCow;
• When contacting StartupCow to make inquiries or complaints;
• When participating in various promotions, contests, or lucky draws through StartupCow;
• To assist in staff training, service quality improvement, and inquiry handling, your conversations with our customer service staff may be recorded.

Types of Personal Data
The personal data collected by StartupCow includes, but is not limited to, the following:

• Data required to verify your identity, including copies of identity documents and document numbers;
• Contact details such as telephone number/email address;
• Your proof of address, including proof of address and/or copy of tenancy agreement;
• Your selfie for online identity verification;
• Notes or recordings of your calls to the StartupCow hotline;
• Emails or letters you send to StartupCow.

Retention of Personal Data

• Personal data will be retained until the fulfillment of the original purpose for which the data was collected, or a directly related purpose; unless the retention of such personal data is required by any applicable laws or contractual agreements; and
• Based on the above criteria and StartupCow’s internal procedures, personal data will be erased from StartupCow’s electronic, manual, and other storage systems after specified retention periods

Security of Personal Data
StartupCow ensures that your personal data will only be accessible by employees who have a reasonable need to contact you to provide services or for other work-related purposes. We have implemented security measures in compliance with the requirements for protecting personal data to safeguard your personal information.

Use of Personal Data
StartupCow may use and analyze your data for purposes including, but not limited to, the following:

• Verifying your identity;
• Processing your inquiries and providing you with progress updates/latest information regarding the services inquired about;
• Providing services to you and handling services you are already using;
• Assisting you with service inquiries, including investigating and resolving issues affecting service quality;
• Issuing bills to you related to your use of StartupCow services;
• Responding to your inquiries or complaints regarding StartupCow services;
• Maintaining records for reference;
• Promotion and marketing of any StartupCow services;
• Assisting StartupCow in preventing fraud or crime;
• Contacting you when necessary;
• Matters requiring disclosure as required or permitted by law.

Disclosure and Sharing of Personal Data
StartupCow will keep all personal data confidential but may disclose information about you to the following parties:

• Law enforcement agencies, government departments, regulatory bodies, courts, or other organizations as required by law;
• Overseas suppliers;
• Banks or credit card companies;
• Professional advisors (including lawyers and auditors).

Online Collection of Personal Data
StartupCow is committed to protecting the information you provide. However, due to the nature of the Internet, StartupCow cannot provide an absolute guarantee.

Some of our websites may disclose aggregated, non-personally identifiable website visitor statistics to advertisers. Some websites may also collect aggregated information about browsing visitors, such as statistics including the number of visits. This information may include, but is not limited to, browser type and version, operating system, IP address, and/or domain name.

Unless stated otherwise, when you browse this website, we only collect your visit records and do not collect any personal data from you. Cookies (if any) used in any part of our website are not used to collect personal data. Cookies are small computer files that can be stored in a web user’s computer, serving to obtain configuration information and analyze the browsing habits of web users. Once a user stores Cookies, re-registration is not required for subsequent visits to the website. Websites often use Cookies to track users’ preferred website topics. You can modify your relevant Internet options or browser preference settings on your computer system to refuse to accept Cookies. However, you may not be able to use or activate certain functions provided by our website as a result. Our website may block users who do not accept Cookies.

To provide browsers with more information and services, StartupCow may provide links to other websites (“Third Parties”). These Third Parties may collect your personal data (such as your name, telephone number, and email address) when you use their services. They will comply with their own Privacy Policies when collecting personal data. The StartupCow Privacy Policy does not bind these Third Parties. 

Access to and Correction of Personal Data

According to the Ordinance, and except for the exemptions specified therein, each customer has the right to:

• Check whether StartupCow holds their personal data and obtain a copy of that data;
• Require StartupCow to correct any inaccurate personal data relating to them;
• Be informed of StartupCow’s policies and practices regarding personal data, and be notified of the nature of the personal data held by StartupCow.
• In accordance with the provisions of the Ordinance, StartupCow has the right to charge a reasonable fee for handling a data access request.

Enquiries
If you have any inquiries regarding this statement, please feel free to contact us.

Email: [email protected]

Revision Date: January 2020