Personal Data and Privacy Statement of Premium Motors Limited

1. General

• 1.1 This statement provides information on the policies of Premium Motors Limited (“our Company”) under the Personal Data (Privacy) Ordinance (Cap.486) of Hong Kong (“Ordinance”).
• 1.2 Terms used in this statement shall, unless otherwise specified, be construed in accordance with the Ordinance.

2. Purpose of collection of personal data

• 2.1 The provision of any personal data by you or on your behalf to our Company shall be voluntary and shall be deemed to authorize our Company to collect, retain, update and use your personal data for the purpose of clause 2.2 below.
• 2.2 The personal data provided by you or on your behalf to our Company from time to time as well as all other personal data related to you collected and held by our Company will be used for the following purposes:
  
  (a) Arranging for vehicle registration, insurance, hire purchase and/or leasing of the vehicles;
  (b) Providing maintenance, repair and other after-sale services of vehicles;
  (c) Providing other goods, facilities and services to you from time to time;
  (d) Collecting any outstanding amount payable by you;
  (e) Providing to the authorized service dealer granted by the above companies including but not limited to Dah Chong Hong (Motor Service Centre) Limited, for conducting maintenance, repair and other after-sale services; 
  (f) Conducting marketing of any goods or services provided by Dah Chong Hong Holdings Limited, its subsidiaries, affiliates and associated companies (“DCH Group”);
  (g) Comparing the personal data provided by you with your other information possessed from time to time by any other member of DCH Group for verification purposes;
  (h) Conducting statistical surveys, marketing research and studies;
  (i) Conducting financial audit; 
  (j) Achieving any other lawful purposes relating to any of the aforesaid purposes; and
  (k) Enforcing any legal or other rights of our Company may have against you.
• 2.3 In the event that, in the opinion of our Company, the personal data provided by you is insufficient or our Company is not satisfied that such data is true and accurate, our Company reserves the right to refuse to withhold process of your application or provision of any service to you unless and until the personal data required by our Company is provided.
• 2.4 For the purposes stipulated in clause 2.2 above, any employee of our Company or any person retained by our Company shall be entitled to inspect the personal data provided by you.

3. Use of personal data

• Our Company will ensure the confidentiality of collected personal data but may provide such information to the following parties (including parties within as well as outside the Hong Kong Special Administrative Region (“Hong Kong”)) for the purpose of implementing the “purpose of collection of personal data” mentioned above:
  
  (a) Any agent, contractor or third party service provider who provides administrative, telecommunications, computer, or other services to our Company and our Company’s customers;
  (b) Any agent authorized by our Company from time to time to process personal data of our Company’s customers;
  (c) Any business partner selected by our Company;
  (d) Any other members of our Company, within as well as outside Hong Kong;
  (e) Auditors, consultants or legal adviser(s) of our Company, within as well as outside Hong Kong;
  (f) Any other person under a duty of confidentiality to our Company; and
  (g) Any of the actual or proposed assignees or transferees of our Company.

4. Duty of confidentiality

• 4.1 Our Company shall exercise reasonable endeavours to ensure that the personal data provided by you shall be kept confidential and be placed in secure locations. Our Company shall further exercise reasonable endeavours to ensure the integrity, prudence and competence of the persons who have access to such data.
• 4.2 In compliance with any law in Hong Kong, our Company may disclose the personal data provided by you to governmental authorities or other regulatory bodies or persons.

5. Special provisions for personal data held by our Company on the internet

• 5.1 By assessing our Company through its website (“Site”), you shall be deemed to agree to the terms and conditions in this statement.
• 5.2 All reasonable efforts are made to ensure that any personal data held by our Company from time to time through the Site is stored in secure and safe storage.
• 5.3 Our Company may use “cookies” on the Site so as to:
• (a) enable tighter security;
• (b) enable you to complete the application process;
• (c) personalize the Site for you; and
• (d) build online profile for you.
• 5.4 You may disallow “cookies” at any time on your web browser.

6. Your rights

• 6.1 In the event that you have objections to any use of the personal data in accordance with clause 2 or any provision or disclosure of such data in accordance with clause 3 above, please inform our Company in writing. The address of our Company is stated in the relevant forms/contracts executed between you and our Company. Our Company shall cease the use and/or provision or disclosure of such data upon confirmation of your request.
• 6.2 Unless you request our Company to dispose all personal data provided by you, you acknowledge that our Company shall retain all such personal data and may continue to deliver to you marketing information even after cancellation or withdrawal of your application for membership of any of the clubs organized by our Company or your membership in such clubs, expiry of the warranty period of any goods supplied or service provided by our Company or completion of any sale of goods or provision of services by our Company (as the case may be).

7. Access and correction request

• 7.1 You have the right to request access to and correction of your personal data in accordance with the Ordinance.
• 7.2 In the event that you intend to correct any personal data, please inform our Company to which you provided your personal data in writing so that our Company shall be able to make the amendments accordingly.
• 7.3 Enquiries concerning the personal data collected, including access and corrections, should be addressed to the address stated in the relevant forms/contracts executed between you and our Company or any other address from time to time stipulated by our Company.
• 7.4 In accordance with the terms of the Ordinance, our Company has the right to charge a reasonable fee for the processing of any data access request. You agree to pay such fees.

8. Use of personal data in direct marketing

Our Company intends to use the customer's personal data in direct marketing and may not so use the data unless our Company has received the customer's consent (which includes an indication of no objection) to such intended use. In this connection, please note that: -

• (i) the name, contact details, products and services portfolio information, transaction pattern and behaviour, consumption preference, financial background and demographic data of the customer held by our Company from time to time may be used by our Company in direct marketing;
• (ii) the following classes of goods, facilities, services, and other marketing subjects may be marketed by our Company, namely:
• (a) brand activities, car show, customer activities, motor related services and products, offers and privileges for motor-related insurance, offers and privileges for motor sales and aftersales services, online shop, redemption gifts;
• (b) loyalty, reward or privileges programs and related services and products;
• (c) services and products offered by the Company’s co-branding / joint promotion business partners including apparel and accessories, art & culture, auction, baby & child caring, banking & financing, beauty, concierge, credit card services, decoration, education, electronic and electrical products, energy, engineering, entertainment, environmental protection, fashion, food & beverages, furniture & equipment, group buying, health and wellness, hotel and catering, household, information technology, insurance, jewelry & watches, lab & R&D, lubricant & petroleum, luxury goods, manufacturing, medical, pets related, planning & design, private club, professional service, property & real estate management, publication & media, social networking, sports, telecommunication, transportation and logistic, travelling, wedding;
• (d) donations and contributions for charitable and/or non-profit making purposes;
• (iii) the above goods, facilities, services and marketing subjects may be provided or solicited by our Company and/or:
• (a) any subsidiary, affiliate or associated company of Dah Chong Hong Holdings Limited;
• (b) any third party goods and/or services provider;
• (c) any third party reward, loyalty, co-branding or privileges programme provider; and
• (d) any charitable organization;
• (iv) in addition to marketing the above goods, facilities, services and other marketing subjects by itself, our Company also intends to provide the above personal data to all or any of the persons described in sub-paragraph (iii) above for use by them or it in marketing those goods, facilities, services and other marketing subjects, and our Company may not so provide the data unless our Company has received the customer's consent (which includes an indication of no objection) to the intended provision.

If the customer does not wish our Company to use or provide to any other persons his personal data for use in direct marketing as described above, the customer may exercise his opt-out right by notifying our Company, in which event our Company must, without charge to the customer, cease to use or provide to other persons the customer's personal data for use in direct marketing.

The customer may provide his consent to the Company's using or providing to other person his personal data for use in direct marketing as described above by notifying our Company's Data Protection Officer, whose contact details are set out below, or through such other channel which the customer may be advised of when providing personal data to our Company.

9. Data protection officer of our Company

The person to whom requests for access to data or correction of data or for information regarding our Company's privacy policies and practices and kinds of data held and for any other communications hereinabove described are to be addressed is as follows: -

The Data Protection Officer
1/F, DCH Building, 20 Kai Cheung Road, Kowloon Bay, Hong Kong
Tel: 2262 1316 Fax.:2171 2154 E-mail: crm@audipml.com.hk

1. What are cookies
   
   

   Cookies are text files sent by a web server (namely, the computer that “hosts” the visited website) to the user’s browser (Internet Explorer, Firefox, Google Chrome, etc.) and stored on the device, either fixed or mobile (computer, smartphone, tablet), used by the user for browsing. Cookies allow the Website to identify the user’s device through the stored information each time the user reconnects itself to the Website through that device.
   
   By using cookies, it is possible to make it easier for the user to browse the Website and to analyse their preferences and tastes by checking their browsing history, and consequently to offer products and provide services more consistent with the interests and expectations of said user.
   
   Cookies may be “session cookies” (when they are stored only for the duration of the browsing session and are cancelled when the session is closed), or “permanent cookies” (that are stored for longer periods, until their expiry or cancellation by the user). Further, cookies may be installed by the website the user is visiting (so-called first party cookies) or may be installed by other websites (so-called third party cookies).
   
   Cookies do not collect direct personal data information concerning the user. In fact, Audi PML cannot, by means of cookies, directly obtain any personal data information (e.g. name, surname), unless expressly provided by the client.
   
   

2. Cookies used by Audi PML
   
   

   Browsing or session technical cookies
   
   Audi PML uses browsing or session technical cookies to allow normal and efficient browsing and use of the Website. Such cookies do not require the preventive and express consent of the user since they are closely linked to the provision of the service requested by the user of the Website. 
   
   Analytical cookies
   
   Audi PML, in its capacity as manager of the Website, uses third parties’ analytical cookies to collect information on the Website used by the users (number of visitors, visited pages, permanence on the Website, etc.) to prepare statistical analysis, on an aggregated basis, on the number of users and on how users browse our Website. To use such cookies, criteria for masking the source of the IP address have been adopted.
   
   Such cookies do not require the prior and express consent of the user since they are closely linked to the provision of the service requested by the user of the Website. 
   
   Third party profiling cookies
   
   Audi PML uses third party profiling cookies (namely cookies that are issued and managed by parties other than Audi PML) to send advertising messages in line with the preferences manifested by the user while browsing.
   
   This category of cookies includes third party social media cookies that allow information on the user’s social network use to be collected.
   
   The use of such cookies requires the express and informed consent of the user. 
   
   

3. Managing your choices about cookies
   
   

   Upon accessing any page of the Website, a banner including some brief information on the cookies used by Audi PML is displayed. By providing your authorisation through the banner, you consent to the use of profiling cookies.
   
   Please note that your consent will be required only upon your first access to the Website: afterwards, due to the use of a technical cookie, we will store your consent to allow you to directly access the Website pages on your return (without prejudice to your right to disable/enable the cookies or to delete them at any time: in this case, on your return, the Website will require your consent once more).
   
   It is possible to disable/enable or delete the cookies at any time by using the settings of your Web browser. In particular, if you do not wish to receive cookies, it is possible to set your own browser to inform you of the presence of a cookie, thus allowing you to decide whether to accept it or not; you may also automatically refuse all the cookies by enabling the specific browser option. You may also delete specific cookies already stored in the browser or block the storage of cookies on your computer by specific websites, or block third party cookies.
   
   Below, find the methods provided by the main browsers:
   
   - Internet Explorer
   - Chrome
   - Firefox
   - Safari 
   
   Following the disabling of all cookies, some functions of the website pages may not operate correctly.
   
   

4. Data Protection Officer of our Company
   
   

   Audi PML acts as Data Controller, with registered office in Kowloon Bay, Hong Kong (9/F, DCH Building, 20 Kai Cheung Road, Kowloon Bay, Hong Kong), tel. +852 2262 1316. You can also contact our Data Protection Officer via email at crm@audipml.com.hk. 
   
   For further information on the processing of your personal data through the Website, please visit the Privacy Policy.