We pledge to meet fully, and where possible exceed, in complying with the requirements of the Personal Data (Privacy) Ordinance (Chapter 486 of the Laws of Hong Kong). In doing so, we will ensure compliance by our staff with the strictest standards of security and confidentiality.Collection of Personal Information
Personal information means any information that is related to an identified person, or that may be used to identify an individual. Examples of the information we may collect include, but not limited to: first and last name; email address; a home, postal or other physical address or other contact information; title, gender, occupation, industry, or personal interests; and other personal information necessary or useful to provide a product or service that you have requested.Website Visitors
Like most website operators, Penana collects non-personally-identifying information of the sort that web browsers and servers typically make available, such as the browser type, language preference, referring site, and the date and time of each visitor request. Penana’s purpose in collecting non-personally identifying information is to better understand how Penana’s visitors use its website. From time to time, Penana may release non-personally-identifying information in the aggregate, e.g. by publishing a report on trends in the usage of its website. Penana also collects potentially personally-identifying information like Internet Protocol (IP) addresses. Penana does not use such information to identify its visitors, and does not disclose such information, other than under the same circumstances that it uses and discloses personally-identifying information, as described below.Gathering of Personally-Identifying Information
Certain visitors to Penana’s websites choose to interact with Penana in ways that require Penana to gather personally-identifying information. The amount and type of information that Penana gathers depends on the nature of the interaction. For example, we ask visitors who sign up for Penana.com to provide a username and email address. In each case, Penana collects such information only insofar as is necessary or appropriate to fulfill the purpose of the visitor’s interaction with Penana. Penana does not disclose personally-identifying information other than as described below. And visitors can always refuse to supply personally-identifying information, with the caveat that it may prevent them from engaging in certain website-related activities.Aggregated Statistics
Penana may collect statistics about the behavior of visitors to its websites. For instance, Penana may monitor the most popular collections on Penana.com. Penana may display this information publicly or provide it to others. However, Penana does not disclose personally-identifying information other than as described below.Protection of Certain Personally-Identifying Information
Penana discloses potentially personally-identifying and personally-identifying information only to those of its employees, contractors and affiliated organizations that (i) need to know that information in order to process it on Penana’s behalf or to provide services available at Penana’s websites, and (ii) that have agreed not to disclose it to others. Some of those employees, contractors and affiliated organizations may be located outside of your home country; by using Penana’s websites, you consent to the transfer of such information to them. In addition, in some cases we may choose to buy or sell assets. In these types of transactions, user information is typically one of the business assets that is transferred. Moreover, if Penana or substantially all of its assets were acquired, or in the unlikely event that Penana goes out of business or enters bankruptcy, user information would be one of the assets that is transferred or acquired by a third party. You acknowledge that such transfers may occur, and that any acquiror of Penana may continue to use your personal and non-personal information only as set forth in this policy. Otherwise, Penana will not rent or sell potentially personally-identifying and personally-identifying information to anyone.
Other than to its employees, contractors, service providers and affiliated organizations, as described above, Penana discloses potentially personally-identifying and personally-identifying information only when required to do so by law, or when Penana believes in good faith that disclosure is reasonably necessary to protect the property or rights of Penana, third parties or the public at large. If you are a registered user of a Penana website and have supplied your email address, Penana may occasionally send you an email to tell you about new features, solicit your feedback, or just keep you up to date with what’s going on with Penana and its products. If you send us a request (for example via a support email or via one of our feedback mechanisms), we reserve the right to publish it in order to help us clarify or respond to your request or to help us support other users. Penana takes all measures reasonably necessary to protect against the unauthorized access, use, alteration or destruction of potentially personally-identifying and personally-identifying information.
You should also be aware that some elements of User Information are made available to other users (e.g., if you publish information to your public profile). If you submit information to our web site such as “stories”, “comments”, “discussion” or “idea exchange”, such information will be visible to other users, meaning that you lose any privacy rights you might have with regards to that information. Such disclosures may also increase your chances of receiving unwanted communications.Personal Information Released to Outside Parties
We do not sell, trade, or otherwise transfer to outside parties your personally identifiable information. In some instances we may employ or cooperate with other companies and individuals to perform functions on our behalf. Examples include fulfilling orders, delivering packages, sending postal mail and e-mail, removing repetitive information from customer lists, analyzing data, providing marketing assistance, providing search results and links (including paid listings and links), processing credit card payments, and providing customer service. They have access to personal information needed to perform their functions, but may not use it for other purposes. As a good corporate citizen, Penana complies with applicable law and legal obligations to respond to governmental, law enforcement and court requests for personal information and other information and data about our visitors. Penana and its legal counsel may access and use your personal information and other information or data in the event of a dispute, in response to legal process or law enforcement inquiries, abuse of our website, or violation of our Terms of Service Policy.Cookies
We will take reasonable steps to insure that all data collected is accurate, complete and timely for the purposes for which they are to be used. We urge you to check your profile regularly to insure that such information is accurate, complete and timely.Third Party Sites
We welcome comments and questions on this policy. As stated above, we are dedicated to protecting your privacy, and we will make every reasonable effort to keep your information secure. Questions regarding our policy should be directed via e-mail (firstname.lastname@example.org)
Penana reserves the right to change these terms and conditions at any time without prior notice. Penana reserves the right to make the final decision in case of any disputes.
Updated July 2017