ACHILLES HONG KONG CO., LTD
Unit A, 5/F., Winner Building, 36 Man Yue Street, Hung Hom, Kowloon, Hong Kong

• 2.1 This Personal Data Privacy Policy will inform you as to how we look after your Personal Data and tell you about your privacy rights and how the law protects you. Specifically, this Policy is given to our customers pursuant to the Personal Data (Privacy) Ordinance (Cap. 486 of the Laws of Hong Kong) (“Ordinance”) in relation to the collection and processing of Personal Data (defined hereinafter) by the Company for the Company’s business activities and its compliance with applicable laws.
• 2.2 The Company's Personal Data Privacy Policy (the “Policy”) specifically addresses the Company’s obligation in respect of the applicable data privacy laws and in certain circumstances, the Company is under the obligation to disclose such Personal Data to the regulated authorities. It is important that you read this policy together with any other policy we may provide when we are collecting or processing Personal Data.
• 2.3 The Company may make changes to this policy from time to time. Any changes will be posted on the website of the Company so it is deemed that you agree to such changes by visiting or accessing to the website of the Company.
• 2.4 In the Ordinance, “Personal Data” is defined as “any recorded information relating to a living individual from which his/her identity can be directly or indirectly ascertained”.
  
  For the purpose of compliance with applicable laws, guidelines or requested by regulatory or other authorities in and outside Hong Kong, the user may be requested by the Company to provide Personal Data such as, but not limited to, the following:-
  1. name;
  2. address;
  3. e-mail address; and
  4. other information may be requested by the Company.

The Personal Data provided by the user to the Company will be used by the Company for the following purposes:-

1. to deliver products;
2. to manage customers’ Personal Information;
3. to respond to inquiries, consultations, and feedback;
4. to use statistics to improve website usability;
5. to send catalogs, documents, and informational magazines;
6. to send catalogs, documents, informational magazines, email newsletters, etc.;
7. to provide information on products, services, and events;
8. to contact business partners for business purposes, execute contracts, hold business meetings, etc.;
9. to manage business partners' information;
10. to manage shareholders, including by preparing records in accordance with relevant laws and regulations;
11. to use Personal Data to contact and provide information to job applicants and for other purposes in recruitment and hiring activities;
12. to pay compensation (wages, bonuses, allowances, etc.) to employees, to perform personnel and labor management, and to provide employee benefits;
13. to manage employees’ health;
14. where it is necessary for legitimate interests (or those of a third party) and the user’s interests and fundamental rights do not override those interests;
15. maintenance of particulars and Personal Data in compliance with the applicable laws to the Company in Hong Kong and overseas; and/or
16. any other purposes as the particular user and the Company separately agreed from time to time.

The Company may, as it deems necessary, disclose to its agents, the holding company, affiliates, subcontractors, and the Company's advisers who is under a duty of confidentiality to the Company, such information as is required to provide its services relating to the activities described in Clause 3 above. For the avoidance of doubt, the user provides its/his/her consents to the Company for its transfer of any of the Personal Data provided herein to such party's principal place of business is outside of Hong Kong.

When providing any Personal Data to the Company, please ensure that the Personal Data is accurate and updated by having regard to the user’s obligations under the Ordinance. The Company according to the need may validate the Personal Data provided by the user. Please keep us informed if your Personal Data changes during your relationship with the Company.

• 6.1 All Personal Data collected and held by the Company as controller of Personal Data will be kept confidential and the Company retains the Personal Data of the user for as long as is necessary to fulfil the original or directly related purpose for which they were collected./li>
• 6.2 The Personal Data are securely stored and access to the Personal Data without appropriate authorization are strictly prohibited and authorization are granted only on a “need to know” basis.
• 6.3 The Company will only retain the Personal Data for as long as reasonably necessary to fulfil the purposes be collected for. The Company may retain Personal Data for a longer period in the event of a complaint or if the Company reasonably believes there is a prospect of litigation in respect to the relationship with the user.

• 7.1 You have the right to:-
  1. request access to the Personal Data supplied by you to ascertain whether the Company hold any personal Data;
  2. obtain such Personal Data and may request to correct any inaccurate Personal Data for the purpose for which it is being used;
  3. to delete or remove Personal Data where there is no good reason for the Company continuing to process it. However, that the Company may not always be able to comply with the user’s request of erasure for specific legal reasons which will be notified to the user, if applicable, at the time of the request;
  4. to object to processing where the Company is processing Personal Data for direct marketing purposes;
  5. to suspend the processing of Personal Data if you would like to exercise your rights stated in this paragraph 7.1 (a)(b)(c) above.
• 7.2 The Company will, upon satisfying itself of the authenticity and validity of the access request from you, make every endeavour to comply with and respond to the request within the period set by the Ordinance (i.e. within 40 days after receiving the request).

• 8.1 The Company may use the Personal Data in direct marketing to provide you with marketing information such as events, activities, promotions and offers provided by the Company.
• 8.2 The Company intends to use the following Personal Data in such direct marketing:-
  1. name;
  2. address; and
  3. telephone number, fax number and e-mail address.
• 8.3 The Company will not provide the user’s Personal Data to third parties for their use in direct marketing unless the Company has received your written consent (indicated by you upon your application to membership).

Enquiries concerning the Personal Data provided by the user to the Company, including the request for access, corrections, removal and object or suspension of processing should be addressed to:-

Attention to Personal Data Officer
ACHILLES HONG KONG CO., LTD

Unit A, 5/F., Winner Building, 36 Man Yue Street, Hung Hom, Kowloon, Hong Kong.

The Company will respond as soon as reasonably practicable and in any event within 40 days of such a request. You will not have to pay a fee to access Personal Data (or to exercise any of the other rights). However, the Company may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, the Company could refuse to comply with the request in these circumstances.