PRIVACY POLICY

In accordance with the policies and the codes of practice under the Personal Data (Privacy) Ordinance
Latest update: 01/07/2021

Objectives of this Privacy Policy Statement
This statement sets out the obligations and policies of Popular Holdings Limited (shortened to ‘Popular’) in accordance with the Personal Data (Privacy) Ordinance (shortened to ‘the Ordinance’).
It is to ensure that staff members who have access to personal data will take all reasonable steps to ascertain such data is kept properly and confidential.

Personal data
Popular hold personal data collected from various types of sources (including online media) for the purposes listed in Part 3 of this statement, and ensure that the following personal data will be handled in accordance with the Ordinance.

a. Types of personal data which may be held by Popular:
- Data subject’s name, telephone number and email address
- Name of school the data subject is currently studying at

b. How personal data is collected by Popular:

(i) Popular may collect personal data from data subjects when they:
- visit Popular website (http://www.popular.com.hk/) and other supporting websites;
- participate in competitions; enroll for seminars, promotional events or training courses;

(ii) Popular may conduct desk research to collect personal data. Sources may come from general information on the Internet, government publications, newspapers, magazines, information released by registered organizations and any other information which is open for public inspection.
(iii) Popular may conduct marketing activities to collect personal data. We may also obtain personal data from all kinds of primary research such as sales visits, personal and telephone interviews, focus group discussions, questionnaires and so on.

Purposes of collecting personal data

Purposes for which personal data may be used include:

- sending written notifications in relation to Popular's courses, books, activities, competitions, promotions and events;
- evaluation and further enhancement of our products and services.

The use of data for marketing promotion
The use of data for direct promotion requires the consensus of the data subjects (include an indication of no objection) on that purpose. Data can be used for the following purposes (include but not limited to):

- new services and products
- promotional and marketing materials;
- Conduct survey researches;
- Event invitation;

The use of personal data for direct promotion
Popular collect the personal data including name, telephone number, address for providing the latest information related to the company, such as promotional events, new services and products, and other promotional and marketing materials. Unless we get the consensus from the data subjects (or an indication of no objection), Popular will not use the personal data for such purpose.

Data access and correction requests

a. Under the Ordinance, a data subject has the right to:

- Check whether Popular hold any personal data and get access to such data;
- Retrieve a copy of their data and correct their data.

For access or correction to the data, please make requests in a letter or an email.

14/F, Tsuen Wan Industrial Centre, 220-248 Texaco Road, Tsuen Wan, NT, Hong Kong
Popular Group (Hong Kong Headquarter)
Fax: (852) 2408 8801

b. Popular will reply to the data access or correction requests within 40 days under the Ordinance.
c. Popular may charge an administrative fee, when handling the requests.

Security precautions

a. Popular will try to encrypt all personal data and use encryption for transmission of sensitive data. While striving to protect all personal information, we cannot ensure or warrant the security of any information transmitted to our company in any form.
b. Access to personal data is restricted to those Popular employees who need to use the data and have been trained to handle such data properly and to observe confidentiality.
c. Any person who has access to personal data held by Popular is duty bound under an act of confidentiality to the company, which has in turn undertaken to keep such information confidential.

Protection of children

a. Visitors to the website who are under the age of 18 must obtain permission from parents or legal guardians before undertaking any of the following activities:

- sending out any of their personal information or information of others;
- entering any competitions, games or lucky draws;

b. As the above data may be made public online, it should be noted that the user should only submit a first name or initials instead of a full name, even with the permission from parents or legal guardians.

Exemption

a. Nothing stated in this Policy shall limit the rights of any data subject under the Ordinance. However, there are certain exemptions. They include exemptions from subject access and use limitation requirements of the Ordinance where their application is likely to prejudice certain competing public or social interests, such as: security, defense and international relations; prevention or detection of crime; assessment or collection of any tax or duty; news activities; and health.

b. Popular reserve the right to change this policy at any time but will notify the concerned parties on the website homepage, or by email, fax, or mail for any updates.

If you do not wish to receive any promotional materials from Popular, please write a letter or an email to:

14/F, Tsuen Wan Industrial Centre, 220-248 Texaco Road, Tsuen Wan, NT, Hong Kong
Popular Group (Hong Kong Headquarter)
Fax: (852) 2408 8801