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Personal Information Collection Statement

  1. General
       

    • 1.1 The protection of our clients’ interests and the security and confidentiality of our clients’ information is at the heart of what we do. We will protect your personal data as a core value and principle of our practice.
       
    • 1.2 This personal information collection statement (“Statement”) informs you:
       

      1. of the purpose for which your personal data (“Personal Data”) collected by us in connection with your use of our services and this website will be used following collection;
         
      2. to whom your Personal Data will be transferred; and
         
      3. to whom you may address Personal Data access or correction requests.
  1. Types of Personal Data we collect
       

    • 2.1 The categories and types of Personal Data Tanner De Witt may collect are:
       
      1. IP address or other unique device identifiers;
         
      2. full name;
         
      3. email address;
         
      4. telephone number;
      1. address;
         
      2. country of nationality or citizenship; and
         
      3. photograph, audio or visual images or recordings.
    • 2.2 It is voluntary for you to provide the Personal Data we have requested. However, failure to receive the Personal Data from you may result in Tanner De Witt being unable to provide effective legal services to you, or to include you in our marketing and business development activities.
       
    • 2.3 You must ensure that all information provided to us is accurate, complete and up-to-date. Personal Data you provide that is inaccurate or incomplete may adversely affect how we engage with you in the course of our business.
  1. Purpose and use
       

    • 3.1 We may collect, hold, process, transfer and use your Personal Data for any of the following purposes:
       

      1. to provide legal services to clients or prospective clients;
         
      2. to register you as a client of Tanner De Witt;
         
      3. to review and process your job application, if you have applied for employment with us;
         
      4. to process payments, billing and collection;
         
      5. to manage access to our premises and for security purposes;
         
      6. to protect the security of our communications and other systems;
         
      7. to collect information about your preferences to improve the quality of our communications with you;
         
      8. to request you to act as a referee for Tanner De Witt in professional surveys or directories;
         
      9. to establish, exercise or defend our legal rights or for the purpose of legal proceedings;
         
      10. to comply with legal and regulatory obligations (including anti-money laundering obligations);
         
      11. for insurance purposes;
         
      12. to record and monitor your use of our website or our other online services for our business purposes (including analysis of usage, measurement of site performance and generation of marketing reports);
         
      13. for legitimate business interests and purposes (including risk management, client relationship management, credit control management, business research and analysis, and other business purposes);
         
      14. to prevent and respond to actual or potential security threats, fraud or illegal activities;
         
      15. to review and respond to any complaints or queries you may have; and
         
      16. for other directly related matters in the conduct of our business.
         
    • 3.2 We may also obtain your Personal Data in the course of providing you with our legal services or conducting our business, including from other publicly available sources (such as media providers, LinkedIn and similar social media platforms, and public registries).
       
    • 3.3 If we provide services or interact with you in the course of your employment, office or engagement with a company or business entity, we may directly market our services to you in that capacity and for the use of that company or business entity.
       
    • 3.4 Your Personal Data will generally be kept confidential and will not be disclosed to any other person without your consent, except for the purposes notified in this Statement for which your Personal Data was collected or if we are required to do so by applicable laws, regulations or professional rules of conduct. Tanner De Witt does not sell Personal Data you provide to us to any third-party.
       
    • 3.5 Personal Data collected by us may not be used for other purposes, unless:
       

      1. you have expressly given your consent to the use for the relevant other purposes;
         
      2. the purpose is directly related to the purpose for which the Personal Data was collected; or
         
      3. we are permitted to use the Personal Data for other purposes arising from an exemption or otherwise in accordance with applicable law and regulation.
  1. Transfer
       

    • 4.1 We may transfer your Personal Data to:
       

      1. our employees, partners and officers;
         
      2. any other entity that is controlled by Tanner De Witt and their employees and officers;
         
      3. our insurers, bankers, auditors and external legal and financial advisors;
         
      4. other service providers, suppliers, business partners and sub-contractors engaged by us in connection with the operation of our business such as:
         

        1. administrative service providers;
           
        2. human resource providers;
           
        3. telecommunications providers;
           
        4. IT services and software suppliers;
           
        5. data analytics providers;
           
        6. data entry and processing service providers; and
           
        7. cloud service providers;
           
      5. barristers, solicitors, other legal representatives, experts and other service providers engaged in a matter in which we are acting, which may include foreign law firms;
         
      6. directories for ranking of professionals;
         
      7. any professional body, regulator, or government body to whom Tanner De Witt is under an obligation or otherwise required to make disclosure under the requirements of any applicable law or regulation or as a matter of proper professional practice;
         
      8. any enforcement authority to whom Tanner De Witt believes it appropriate to make disclosure;
         
      9. persons or companies seeking references in respect of you, provided you have given your prescribed consent;
         
      10. business contacts of Tanner De Witt in the course of performing our legal services for you (including marketing and business development activities); and
         
      11. companies providing services for anti-money laundering and terrorist financing checks, credit risk reduction and other fraud and crime prevention purposes.

       

    • 4.2 Some persons to whom we transfer your Personal Data may be located outside Hong Kong, in locations that may not have in place data protection laws which are substantially similar to Hong Kong, and this may mean your Personal Data may not be protected to the same or similar level as that in Hong Kong.
  1. Cookies
       

    • 5.1 A cookie is a small data file that a web site can send to your computer or device when you visit the Tanner De Witt website.  You can find more information about cookies in this publication of the Privacy Commissioner for Personal Data, Hong Kong.
       
    • 5.2 Cookies are used to make websites work in a better, more efficient way, usually by enabling them to recognise you and remember important information that will make your use of a website more convenient (e.g. by remembering your user preferences).
       
    • 5.3 We use cookies to:
       

      1. remember your preferences on language, font size, colour scheme, so that the look and feel of our website is kept for your future visits;
         
      2. analyse how you navigate our website to help us optimise its design;
         
      3. track your behaviour and preferences so we can assess the kind of information and services you may be interested in from Tanner De Witt.

       

    • 5.4 We use:
       

      1. session cookies which are unique to each visit you make to our website; and
         
      2. persistent cookies which will not be deleted when you close your browser window and will be activated every time you visit our website.

       

    • 5.5 The cookies we use are either:
       

      1. necessary cookies which are essential to our website to help you to move from page to page and use our website’s features;
         
      2. functionality cookies which allow our website to remember choices you make, and provide more personal features; or
         
      3. performance cookies which collect information about your use of our website and help us to improve the way it works.

       

    • 5.6 We use a limited number of third-party cookies, including:
       

      1. Google Analytics cookies: These cookies are used by Google Analytics to monitor traffic levels, search queries and visits to our website.  Google Analytics stores internet protocol (“IP”) addresses on its servers in the US.  These cookies enable Google to determine whether you are a return visitor to our website, and to track the pages that you visit during your session. The information generated relating to our website is used to create reports about the use of the website. Google hold this information and provide us access to it.  This is the link to Google’s privacy policy.
         
      2. E-marketing cookies: We use third-party applications from Zoho (cookie policy here) to send out marketing communications via email. If you click through from one of our emails to our website, we use additional cookies to connect your email to your use of our website.
         
      3. LinkedIn Insight cookies: The LinkedIn Insight Tag is a piece of lightweight JavaScript code that enables LinkedIn campaign reporting and insights about website visitors. Its main uses are to track conversions, retarget website visitors, and unlock additional insights about LinkedIn members’ ad and website interactions.

       

    • 5.7 By continuing to use our website without notifying us of your refusal to use cookies or withdrawing your consent, you are agreeing to our use of cookies.
       
    • 5.8 You may refuse the use of cookies or withdraw your consent at any time by selecting the appropriate settings on your browser.  These settings are usually found in the “options” or “preferences” menu of your internet browser, or by clicking “help” on your browser menu.  Removal of cookies may affect your use and experience of our website.
       
    • 5.9 We only retain cookies for the duration needed for the function they are used.  This function varies according to the cookie.
  1. Access and correction
       

    • 6.1 You have the right to:
       

      1. request a copy of your Personal Data held by us, unless we are exempted from complying with a data access request; and
         
      2. request for us to make necessary corrections in respect of any Personal Data that you consider inaccurate after we have fulfilled a data access request from you. We may refuse a data correction request if we believe the Personal Data is accurate, an expression of opinion or the proposed correction is inaccurate.

       

    • 6.2 If you wish to access or correct your Personal Data, please contact our Data Protection Officer by email at [email protected] or by post to:

      •  
      Data Protection Officer
      Tanner De Witt
      17/F Tower One, Lippo Centre
      89 Queensway, Admiralty
      Hong Kong
       

    • 6.3 We reserve the right to charge a reasonable fee for processing any access or correction request.
  1. Additional information
       

    • 7.1 This Statement is intended to notify you of key points about your Personal Data by your use of our website. Learn more about our privacy policies at Tanner De Witt by contacting [email protected] and requesting the Privacy Policy relevant for you.
       
    • 7.2 Tanner De Witt may revise this Statement by amending this page. You should check this page from time to time to take notice of any changes we make.
       
    • 7.3 Tanner De Witt complies with the Personal Data (Privacy) Ordinance (“Ordinance”). Please visit the website of the Privacy Commissioner for Personal Data, Hong Kong (pcpd.org.hk) for more information about personal data privacy in Hong Kong.
       
    • 7.4 “Tanner De Witt”, “we”, “our” or “us” refer to the Hong Kong solicitors firm of Tanner De Witt. Tanner De Witt is regulated by the Law Society of Hong Kong. Tanner De Witt is the data user.