Privacy Policy (including Personal Information Collection Statement) 
CK Hutchison Holdings Limited

CK Hutchison Holdings Limited (“CK Hutchison”), incorporated in the Cayman Islands with limited liability, takes your privacy very seriously. We have created this privacy policy to ensure that you understand how your personal data will be used and that you understand your rights under the Personal Data (Privacy) Ordinance, Laws of Hong Kong (Cap 486) (the “PDPO”).

This privacy policy applies to all personal data we collect through the website sphere.ckh.com.hk (the “Site”) or through your interactions with the editorial team of the website. If you do not agree with this policy, then you should either not use the Site or contact us using the details under the section ‘CONTACT DETAILS’ to request that we cease using your personal data. It is important that you read this policy as well as any other personal information collection statements and privacy notices we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This policy supplements other notices and policies of CK Hutchison and is not intended to override them.

Please note that this privacy policy may be amended from time to time without prior notice. If we amend this privacy policy, we will post the amended policy on this page, so you are always aware of what information we collect, how we use it and under what circumstances we may disclose it.

If there is any inconsistency or conflict between the English and Chinese versions of this policy, the English version shall prevail.

WHO WE ARE

CK Hutchison is the data user and is responsible for your personal data (and is collectively referred to as “company”, “we”, “us” or through “our” in this privacy policy).

CONTACT DETAILS

If you have any questions about this privacy policy or our privacy practices, or wish to exercise any of the individual rights outlined in the section ‘YOUR RIGHTS’ below, please contact us as follows:

WHY WE COLLECT PERSONAL DATA

We collect and store personal data about you if you voluntarily submit it to us. In particular, we collect some or all the following information should you choose to complete the ‘Subscribe for Updates’ form (the “Subscription Form”) in order to apply to receive notifications of new content from the Site. 

These are voluntary activities on your part. However, if you choose not to provide us with the requested personal data, you will not be able to complete your application to receive periodic notifications of content updates of the Site. When collecting other personal data from you in other scenarios we will also indicate whether the provision of that personal data is voluntary or obligatory, and the consequence for you if you choose not to provide the requested personal data.

If you contact us via any of the means provided on the ‘Contact Us’ page on the Site or any communications we send to the subscribers to the Site, we will also collect any other information you provide in your communications to us.

As you interact with the Site, we will automatically collect data about your browsing actions and patterns for the purpose of maintaining the functionality of the Site (and webcasts or other live streaming formats) and to inform us on how to enhance your experience. We collect this personal data by using cookies and similar technology. Please see the section ‘COOKIES AND SIMILAR TECHNOLOGY’ below for further details.

HOW WE USE YOUR PERSONAL DATA

We will only use your personal data:

• for the purposes set out in the next section ‘PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA (‘PERSONAL INFORMATION COLLECTION STATEMENT’)’;
• where you have given your consent in advance for your personal data to be processed for another, different purpose; or
• where permitted by law.

You have a right to withdraw your consent at any time by contacting us. If you withdraw your consent, such withdrawal does not affect the lawfulness of any processing that we carried out prior to that withdrawal.

PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA (‘PERSONAL INFORMATION COLLECTION STATEMENT’)

We may also use the personal data you provide to us for any of the purposes described in this section. 

If you choose to submit a Subscription Form, we will use the personal data that you submit in that form to notify you from time to time regarding new content updates of the Site. These updates may not be regular nor immediately follow the publication of new content. 

If you contact us via any of the means provided on the ‘CONTACT US’ section or any communications we send to the subscribers of the Site and request for us to contact you, we will use your personal data to contact you as requested.

We may also compile and store any of the contact information or other personal data you provide us with. We may use that information, together with any other personal data we already hold about you, in whole or in part when fulfilling any of the purposes described in this privacy policy.

We may also use the personal data you submit (including your personal data) where it is necessary for our legitimate interests (including in order to administer and protect (such as troubleshooting, data analysis, system maintenance, etc.) our business and the Site, including webcasts or other live streaming formats provided through this Site or other digital platforms and channels, to deliver relevant website content to you and to measure or understand the effectiveness of the content of the Site (including webcasts, etc.) we provide to you).

When collecting other personal data from you in other scenarios we will also indicate for what purposes we will use that personal data.

We also reserve the right to access and/or disclose any information where such processing is required by laws and regulations, courts or administrative agencies or is necessary to permit us to investigate suspected fraud, harassment or other violations of any law, rule or regulation, the Site rules or policies, or the rights of third parties or to investigate any suspected conduct which we deem improper.

CHANGE OF PURPOSE

We will only use your personal data for the purposes set out in the section ‘PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA (‘PERSONAL INFORMATION COLLECTION STATEMENT’)’ above or a directly-related purpose.

If we reasonably consider that we need to use it for another reason we will seek your prior consent.

DATA RETENTION

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of contacting you where you requested it, for providing you with further information from time to time where you request it, and for satisfying any legal, regulatory, tax, accounting or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

YOUR RIGHTS

You have the right under the PDPO to: 

• check what kinds of personal data about you the company holds;
• access the personal data about you the company holds;
• require the company to correct any personal data which is inaccurate; and
• request a copy of this privacy policy.

To exercise any of these rights, please contact us using the details under the section ‘CONTACT DETAILS’. The company has the right to charge you a reasonable fee for the processing of any personal data access request.

It is important to make sure your personal data is kept up to date. If you wish to change or modify your information previously provided, please contact us using the contact details provided above.

DATA TRANSFERS

We may share your personal data with: 

• our subsidiaries and other affiliates and any other members of the CK Hutchison group (whether domiciled or operating in Hong Kong or abroad) that carry out functions that support us in fulfilling the purposes set out in this privacy policy;
• agents, contractors, sub-contractors and other service providers authorised or engaged by the company or its affiliate who are under a duty of confidentiality to the company or its affiliate or other contractual terms to safeguard your personal data, and who provide administrative, data processing, research and marketing, distribution, telecommunications, IT and content management system development, support and maintenance, web and server hosting, professional or other services to the company or its affiliate;
• domestic and overseas government and regulatory authorities or law enforcement authorities or the courts or arbitration tribunals; and
• our professional advisers.

We may transfer personal data to a purchaser or transferee (or proposed purchaser or transferee) of any of the company’s business or the business of a particular division or line of our business, or any such business of an affiliate (whether through a sale of assets or shares), including for the purposes of any due diligence exercise, subject in each case to our compliance with all applicable legal and regulatory obligations.

SECURITY

We are committed to taking reasonable steps to ensure the security of your information in line with our legal and regulatory obligations. To prevent unauthorised access, maintain data accuracy, and ensure the appropriate use of information, we have put into place appropriate technical and organisational measures to ensure a level of security appropriate to the risk, taking into account the nature, scope, context and purposes of the processing we undertake. However, due to the inherent open nature of the Internet, we cannot guarantee that communications between you and us or information stored on the Site or our servers will be completely free from unauthorised access by third parties such as hackers.

Service providers handling personal data on our behalf will be subject to appropriate contractual obligations to implement appropriate technical and organisational security measures to safeguard the personal data, and to process the personal data only as instructed by us.

COOKIES AND SIMILAR TECHNOLOGY

A cookie is a small data file that is stored on your device when you visit certain websites. We use cookies for basic website functionality and to determine if you have previously visited this website and have already accepted our cookie notice. A cookie file can contain various types of information, including a user ID that the Site uses to track the pages you have visited. We will also collect technical data such as your internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access the Site (including when participating in webcast or other live streaming format).

If you choose to disable cookies or refuse to accept a cookie, you may not be able to utilise all features of the Site.

EFFECTIVE DATE

This privacy policy was last updated on 12 January 2021.