Personal Information Processing and Protection Policy
Last updated on December 29th, 2023
About this statement
This privacy policy statement sets out the data processing practices carried out through your use of this web site by Dezan Shira & Associates Limited (hereinafter referred to as "DSA”) and its subsidiaries.
DSA fully understands the importance of personal information to you and is committed to protecting your personal information. With respect to the way DSA protects your personal information and other related information, DSA has formulated this Personal Information Processing and Protection Policy ("Policy"). Please be sure to read it thoroughly and make proper choice. By using our Services, or communicating with us about them, you are accepting and consenting to the practices described in this Privacy Policy, including any updates and amendments. If you do not agree to the terms of this Privacy Policy, you must not access or use our Services or communicate with us about them. Your use of our Services and any dispute over privacy is subject to this Privacy Policy and any applicable Terms of Use, including any terms available at http://www.dezshira.com and/or any other agreements. In the event that the provisions of any such agreements differ from or conflict with the provisions of this Privacy Policy, the applicable terms or agreement will apply.
If you have any requests concerning your personal information or any queries with regard to these practices please contact us.
Definition of Personal Information
"Personal Information" refers to all kinds of information related to an identified or identifiable natural person, recorded electronically or by other means, excluding information that has been anonymized.
"Sensitive Personal Information" refers to Personal Information that, once leaked or illegally used, may easily lead to the infringement of a natural person's human dignity or endanger his or her personal and property safety, including biometrics, religious beliefs, specific identities, medical and health information, financial accounts, whereabouts and other information, as well as Personal Information of minors under 14 years old.
“Processing” of Personal Information includes the collection, storage, use, processing, transmission, provision, disclosure and deletion, etc. of personal information.
Application scope
This Policy applies to:
- your Personal Information obtained online when you use DSA’s website;
- your Personal Information obtained when you purchase and/or use DSA 's products and services, and
- you provide your Personal Information to DSA when establishing contact with DSA.
DSA’s official website may contain links to third-party websites. The related products or services of such third-party websites are not governed by this Policy. DSA suggests that when you visit such third-party websites, you should review their Personal Information policy to understand their Personal Information practices.
Type of Personal Information to be collected
The Personal Information DSA collect includes, but is not limited to, your name, email address, IP address, phone number, territory and regions, workplace, social media accounts such as WeChat and other information.
DSA does not actively collect Personal Information from minors under the age of 14 on an individual basis, unless otherwise required by laws, regulations and law enforcement agencies. If you think DSA has collected information of a minor, please contact us in time, and we will delete such Personal Information promptly after verification.
About the use of cookies
Cookies may be used by us to provide you with customized information from our web site. A cookie is an element of data that a web site can send to your browser, which may then store it on your system. Cookies allow us to understand who has seen which pages and advertisements, to determine how frequently particular pages are visited and to determine the most popular areas of our web site. Cookies may also allow us to make our web site more user friendly by, for example, allowing us to save your password so that you do not have to re-enter it every time to visit our web site.
We use cookies so that we can give you a better experience when you return to our web site. Most web browsers automatically accept cookies. You do not have to accept cookies, and you should read the information that came with your browser software to see how you can set up your browser to notify you when you receive a cookie, this will give you the opportunity to decide whether to accept it. If you disable cookies from your browser you may not be able to access certain features of a particular web site.
Purpose of use of Personal Information
DSA will properly use your Personal Information collected from the above-mentioned sources only to the extent minimum necessary to achieve the purposes described below. DSA will obtain your prior consent to use your Personal Information for purposes other than those listed below.
- Identifying potential customers or subscribers.
- Dealing with your requests and enquiries.
- Providing you with information about services offered by Dezan Shira & Associates.
- Processing your application for employment at Dezan Shira & Associates.
- Determining and better understanding the performance of our website and promotional campaigns.
- Delivering conference guides, product and/or service guides;
- Delivering advertisement material or souvenir;
- Responding to various inquiries;
- Conducting customer surveys and analyzing them to improve DSA’s products and services
- Providing Personal Information to DSA’s affiliates or clients in connection with certain business activities carried out in cooperation with them;
- Complying with the requirements of laws and regulations, executing court orders or other legal procedures, or responding to requirements from authorized government agencies.
Storage of Personal Information
DSA will retain your Personal Information for the minimum period required by law and for the period necessary to achieve the purposes described herein, unless otherwise stipulated by law or regulation or specifically required by law enforcement agencies.
Share of Personal Information with third parties
DSA will not provide your Personal Information to a third party without your express permission, with the following exceptions:
- With your prior express authorization;
- When expressly required by law or regulation;
- When your Personal Information is necessary for the urgent purpose of protecting life, preventing personal injury or protecting property, but it is difficult to obtain your consent at the same time;
- When performing related work, tasks and services as provided in the agreement between you and DSA, such as having to submit documents containing your Personal Information to the relevant government departments, institutions to handle the relevant application you entrust;
- When your Personal Information is necessary for the cooperation with the legal work of government agencies, courts or their branch organs, but the time taken for obtaining your consent may hinder the work.
Safeguards for Personal Information
DSA protects your Personal Information in the following main aspects:
- Collection, use and provision of Personal Information: DSA complies with the principles of lawfulness, legitimacy, necessity and good faith in processing of your Personal Information.
- Formulate and publicize Personal Information processing rules: DSA complies with the principles of openness and transparency in making public the rules for processing Personal Information and expressly indicate the purpose, method and scope of such handling.
- Implementation of security systems and measures: In processing Personal Information, DSA always abides by applicable Personal Information protection laws and regulations. To ensure the security of Personal Information processing, DSA will take information security measures in compliance with relevant standards, manage Personal Information, restrict the means of external dissemination of Personal Information and prevent unauthorized access according to relevant systems, and prevent Personal Information leakage to the utmost extent.
- Respecting the rights of information subjects: When you request the disclosure, correction or deletion of your Personal Information, or refuse the use or provision of your Personal Information, DSA will respect the rights of the information subject and respond and handle the relevant request in a timely manner in accordance with the requirements of the corresponding laws and regulations.
- Development and continuous improvement of Personal Information management system
- DSA 's management and employees understand the importance of Personal Information protection. DSA will develop, fully implement and continuously improve relevant Personal Information management systems to ensure the reasonable use and protection of Personal Information.
- DSA is constantly optimizing its organizational and technical measures for Personal Information protection. DSA will strictly limit the access to and use of Personal Information through a sound internal Personal Information management system and will also take necessary security technical measures to protect your Personal Information from unauthorized access, destruction, modification or disclosure.
- The Internet environment is not completely secure. DSA will do its best to ensure and guarantee the security of any information you send us. In the event of an incident endangering network security, DSA will promptly address the security risks, take appropriate remedial measures, and report to the relevant competent authorities in accordance with applicable laws and regulations. At the same time, DSA will, in accordance with the requirements of laws and regulations, promptly inform you of the basic situation and possible impact of the security incident, the measures DSA has taken or will take, and DSA’ remedial measures for you. DSA will inform you of the relevant information of the incident in a timely manner by SMS notification, e-mail, telephone and other contact information reserved by you. If it is difficult to inform you on an individual basis, DSA will make an announcement in a reasonable and effective way, such as issuing a notice on DSA’s official website.
Your data rights and options
- DSA will endeavor to ensure your right to access, update, correct or delete your Personal Information. In the event that laws or regulations require otherwise and DSA is unable to fulfill your request consequently, DSA will provide you with a reasonable explanation.
- Access right: You have the right to access your Personal Information collected in connection with DSA’s provision of products and/or services.
- Right to correction: You have the right to request correction of your Personal Information when you discover that your Personal Information DSA holds is incorrect or incomplete.
- Right of deletion: You have the right to request deletion of your Personal Information when you no longer use DSA’s products and/or services and request deletion of your Personal Information, or when DSA process your Personal Information in violation of laws and regulations or the agreement with you.
- Right of revocation: Some of DSA’s services require basic Personal Information in order to be completed. You may vest or withdraw your authorization and consent at any time.
- In the event that you request to exercise the above-mentioned rights, or make other complaints, DSA will briefly check your identity and the authenticity of your request, and in principle, DSA will reply to you the opinion or result within fifteen (15) business days. Please note that we may not respond to questions that are neither related to this Policy nor related to your rights of Personal Information.
- DSA will not charge for your reasonable request. For repeated requests that exceed the reasonable limit, DSA may reject according to law or request you to assume relevant costs. DSA may reject requests that are not directly related to your identity, that are repeated without reasonable grounds, or that require excessive technical means (such as the development of new systems or fundamental changes to existing practices), that pose a risk to the legitimate interests of others, or that are impractical.
Update process for this Policy
DSA will update this Policy from time to time according to the legal, technical and commercial changes. Once this Policy is updated, DSA will notify you in a manner appropriate to the significance of those changes. You can know the update time through "Last updated on" at the beginning of this Policy.
Contact us
If you have any questions or concerns about how DSA use your Personal Information, please feel free to contact DSA by the following contact information:
Dezan Shira & Associates Limited
Address: Unit 507, 5/F, Chinachem Golden Plaza, 77 Mody Road, Tsim Sha Tsui East, Kowloon, Hong Kong
Contact information: dpo@dezshira.com