Introduction 

This is Dalhousie Governance Limited’s privacy policy.  

Dalhousie Governance Limited (we, our or us) respects your privacy and is committed  to protecting your personal data. This privacy policy will inform you as to how we look  after your personal data when you visit our website (regardless of where you visit it  from) and tell you about your privacy rights and how the law protects you.  

We are legally required to comply with the Personal Data (Privacy) Ordinance (Cap.  486) of the laws of Hong Kong Special Administrative Region when collecting, holding,  using and/or processing your Personal Data. In doing so, we will ensure compliance  by our staff to the strictest standards of security and confidentiality. 

Please read the following carefully to understand our privacy policy and our practices  in relation to how we handle your Personal Data. By using or accessing our website  or providing your Personal Data to us, you confirm your agreement to all of the terms  in this privacy policy and consent to the collection, use, transfer, storage and  processing of your Personal Data as described in this privacy policy. If you disagree  with any part of this privacy policy, please do not continue using or accessing our website. 

1. Collection of Personal Data  

Depending on the type of services we provide to you, we may collect two basic types  of data from you, Personal Data and Non-Personal Data:  

Personal Data means any personally identifying data which we may collect from you  when you seek services from us and includes without limitation names; email, postal  and billing addresses; phone numbers; date of birth; payment information; type of  identification document and full identification document number; account details from  which it is practicable for the identity of an individual to be directly or indirectly  ascertained.  

Non-Personal Data includes aggregate and/or automatic information, which is data  collected about the use of service (including without limitation our website), or about a  group or category of users from which individual identities or other individually  identifiable information has been removed / anonymised. This privacy policy does not  restrict or limit our collection, use, handling and processing of Non-Personal Data.  

The following is a non-exhaustive list of common situations where we may collect and  store your Personal Data: 

• using our services, including without limitation to subscribing to our  communication materials; 
• your interaction and correspondence with us; 
• using and/or browsing our website; and
• sending us an email enquiry or a request for assistance in connection with our  services.  
  
  

2. Processing of Personal Data 

All processing of Personal Data will be conducted according to the data protection  principles as follows: 

• Personal Data must be collected lawfully, fairly and as necessary but not  excessive for a purpose directly related to a function / activity of our business  as notified to you and third parties to whom the Personal Data may be  transferred; 
• Personal Data must be accurate and kept no longer than is necessary to fulfil  the purpose for which they were collected; 
• Personal Data are only used for the purpose for which they are collected or for  a directly-related purpose, unless voluntary and explicit consent is obtained  from you;  
• practicable steps are taken to safeguard Personal Data from unauthorised /  accidental access, processing, erasure, loss or use; and 
• your Personal Data is accessible and will be corrected upon your request.
  
  

   3. Purposes for which we may use your Personal Data  

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

• to provide our services to you in accordance with your instructions or as we  may otherwise consider appropriate and necessary (this may involve disclosing  your Personal Data to third parties for the provision of such services under  paragraph 4 below);  
• to process payments, billing and collection; 
• to comply with legal and regulatory obligations; 
• for our legitimate business interests and purposes (including client relationship  management, credit control management, risk management, business  research and analysis, and other purposes relating to our business and the  provision of our services); 
• for insurance purposes; 
• to maintain the security of our server and system; 
• to review and respond to any enquiries or complaints you may have; and • for other directly-related matters in the conduct of our business. 

Your Personal Data we collect may not be used for other purposes unless (i) you have  expressly given your consent to the use for the relevant other purpose, (ii) the other 

purpose is directly related to the purpose for which the Personal Data was collected, or (iii) we are permitted to use the Personal Data for other purposes arising from an  exemption or in accordance with applicable laws and regulations. 

Where it is legally required, specific consent must be obtained before we process  Personal Data for any specific purpose such as conducting direct marketing, we will  ensure that such specific consent is obtained clearly and explicitly by us for the  specified purpose. 

4. Disclosure and Transfer of Personal Data 

We will take all practicable steps to keep your Personal Data confidential. We will not  disclose, transfer and/or assign such data to any third party except for the following:  

• when necessary for the purposes for which the Personal Data are collected;  • when we have obtained your consent to do so;  
• any agent, adviser, auditor, contractor or third-party service provider who  provides administrative, telecommunications, computer, technology, financial,  payment, fraud prevention, insurance, data processing, internet, cloud service and/or other services to us in connection with the operation of our business  and/or the relevant service(s) that you seek from us, and/or who otherwise  processes Personal Data for and on our behalf;  
• any person (including without limitation government authorities, regulatory or  administrative bodies, or law enforcement agencies) to whom Dalhousie  Governance Limited is under an obligation to make disclosure under the  requirement of any law binding on Dalhousie Governance Limited or for the  purposes of any guidelines or codes of practice issued by regulatory or other  authorities with which Dalhousie Governance Limited is expected to comply, or  such parties who are authorised by law to request information from Dalhousie  Governance Limited;  
• for the protection of our rights and interests; and/or 
• if Dalhousie Governance Limited decides to sell, merge and/or re-organise any  part of its business, to any actual or proposed assignee, transferee or  successor of or to Dalhousie Governance Limited’s rights in respect of your  Personal Data. 

The parties to whom we disclose and/or transfer your Personal Data may be situated outside of Hong Kong where there may not be in place data protection laws which are  substantially similar to, or serve the same purposes as, the Personal Data (Privacy)  Ordinance (Cap. 486) of the laws of Hong Kong Special Administrative Region.  

5. Security and Storage 

Except as mentioned in paragraph 4 above, your Personal Data, however stored, will  be accessed only by our employees or contractors who are authorised to do so. Where  Personal Data is stored electronically, it will be kept on a secured server and will be  encrypted and/or password-protected (or under some equivalent form of protection)  and accessible only by authorised personnel of Dalhousie Governance Limited or its  contractors. Personal Data are treated as confidential information by Dalhousie  Governance Limited and all employees and contractors designated to handle Personal  Data will be instructed to do so only in accordance with this privacy policy. 

6. Retention of Personal Data  

Personal Data provided by you may be retained for as long as the purposes and any  directly-related purposes for which such data were collected continue. Once it is not  necessary to use the Personal Data to fulfil such purposes (and directly-related  purposes), they are then destroyed within a reasonable time unless their retention is  required to satisfy legal, regulatory or accounting requirements or to protect Dalhousie  Governance Limited’s interests. 

7. Cookies 

Our website does not use any cookies. 

8. Links to Other Websites  

Our website may contain hyperlinks linking to other websites (e.g. Linked Sites). If you  click on any of these hyperlinks, you will leave our website for another location. At any  other website, the protection of your privacy, Personal Data and your exposure to  cookies are not our responsibility and you are advised to refer to the privacy policy of  that other location (if any). 

9. Use of Personal Data in legal proceedings  

If it becomes necessary that we have to take action against you for any reason  whatsoever including recovering from you any money you may owe us, you expressly  agree that the Personal Data provided by you can be relied upon in identifying and  taking legal action against you. 

10. Your right to access and correct Personal Data  

You may at any time request access to and correct Personal Data relating to you in  any of our records. You may also ask us to delete your Personal Data from any active  mailing or distribution list or object to our collection and processing of your Personal  Data at any time. 

To exercise any of your rights, contact us at the address or email below marking your  communication “Confidential”. In response, we may ask you to provide certain details  about yourself so that we can be sure you are the person to whom the data refers. We  are legally required to respond to your requests within 40 days. We may also charge  you a reasonable fee for complying with any data access request.  

Any requests (i) for access to data or correction of data, (ii) for general information  regarding our policies and practices with respect to Personal Data, and (iii) about the  kinds of Personal Data that we hold, and/or general questions and complaints relating  to this privacy policy should be addressed to the person below: 

Dalhousie Governance Limited 

Attn: Neil Mackie, Director 

(Marked Confidential) 

Address: 20/F Central Tower, 28 Queen’s Road Central, Central, Hong Kong Email: neil@dalhousiegovernance.com 

We may change this privacy policy from time to time without further notification. Any  changes to this privacy policy will become effective once it is posted on this website.  Your continued use of our website after the posting of such changes indicates your  acceptance of the updated terms.  

Last Updated: April 2022