Please read and review this Policy, which will inform you how GBA LatAm Trade and Investment Advisors Ltd (GBA LATAM) collects, uses, and process and Personal Data. We may also collect and process Personal Data under any exceptions to Applicable Laws, which are not set out in this Policy. We trust that it will assist you in making an informed decision whether to provide us with any Personal Data.
For the purposes of understanding GBA LATAM’s Personal Data Protection Policy (“Policy”), capitalised terms used in this Policy shall have the following meanings:
“Applicable Laws” means Hong Kong SAR Personal Data (Privacy) Ordinance (Cap. 486) and its subsidiary legislations and regulations as amended from time to time;
“Personal Data” means any data, whether true or not, which is (a) about an individual who can be identified (i) from that data; or (ii) from that data and other information to which we have or are likely to have access and would include data in our records as may be updated from time to time, or (b) defined as “personal data” or “personal information” under any Applicable Laws.
“Platforms” means collectively GBA LATAM’s Social Media and Website, and any other websites or applications which we may own or operate from time to time;
“Research Products and Services” means sales of goods or provision of services in relation to any of the following (whether through physical or online channels or in any other media now known or available in the future): business services, publications, insights and market research documents.
“Social Media” means GBA LATAM’s pages and accounts on third party social media platforms such as Facebook and LinkedIn
“Website” means the GBA LATAM website accessed at the following address https://gbalatamtradeandinvestment.com/ ; and
“GBA LATAM” means GBA LatAm Trade and Investment Advisors Ltd.
During our business relationship with your self, we may collect Personal Data. Examples of the types of Personal Data we may collect include name, contact details, mailing address, email address, network and device data, browsing behaviours, and any other personally identifiable information which have been provided or submitted to us, or in the course of any other forms of interaction. We will notify you when you must provide such Personal Data. We may also request other Personal Data from which is not marked as “mandatory” where it is entirely voluntary to provide such Personal Data (though please note that such personal data are used for the purpose of improving our understanding of our Platforms’ and users and providing better products and/or services).
If you provide us with Personal Data relating to a third party by submitting such Personal Data to us, you represent to us that you have obtained the consent of the third party to provide us with their Personal Data for the respective purposes.
By (1) clicking “Yes” on our Policy pop-up or any web form referring to this Policy on any of our online platforms, (2) submitting your Personal Data to us when signing up for an account on the Website, (3) browsing our Website, or (4) ordering any of our products and services, you are agreeing to the terms of this Policy.
We may update this Policy to ensure that it is consistent with industry trends and/or any changes in legal or regulatory requirements. You agree to be bound by the prevailing terms of the Policy as updated from time to time. We will endeavour to notify you by notice on the Website of any material changes to the Policy.
HOW DO GBA LATAM COLLECT SYOUR PERSONAL DATA?
GBA LATAM collects Personal Data from you when you or your company:
- Register an account on the Website;
- Use any of our related services, such as subscribing to our newsletter, product notifications;
- Browse our products and services or otherwise interact with our Website;
- Accept our cookies on your device;
- Interact with our customer experience team or other representatives, for example, via our webform, emails, telephone calls, letters, or face-to-face meetings;
- Interact with us on our Social Media, such as liking our posts, commenting on our posts, private messaging us on our Social Media;
- Participate in our promotions, initiatives or any request for additional Personal Data such as customer surveys;
- Our third-party analytics and other service providers provide your Personal Data to us, which was collected and processed by them and disclosed to us pursuant to their separate privacy policies; or
- When you or your company voluntarily submit your Personal Data to us for any reason.
Please also take note of our Cookies Policy below in respect of the data collected and used by third-party cookies and trackers on our Website.
We may also collect your Personal Data in circumstances where such collection does not require consent under Applicable Laws.
HOW WILL YOUR PERSONAL DATA BE USED?
GBA LATAM may use and disclose your Personal Data for purposes necessary to provide you with our products as services, including to:
- register and maintain your user account and to verify your identity;
- process your order for our Research Products or Services, process or collect your payment for the order;
- provide you with supporting services and functions related to your user account, such as saved items in cart or product notifications;
- communicate with you in relation to (i) your queries, requests and feedback, (ii) material changes to our Website Terms of Service, Policy or other terms and conditions, and (iii) matters relating to the operation of your account;
- personalise and improve your customer experience when you visit the Website, for example by prioritizing products and services appearing in your search results or feed;
- monitor and enforce compliance with our Terms of Service, including dispute resolution;
- comply with (i) internal risk controls, (ii) the terms of our access to payment processing, financial or banking services such as credit card disputes, fraud, billing errors, or (iii) any applicable law; and
- ensure our Website function properly and to improve their performance, by carrying out activities such as debugging, statistical analyses for optimizing our Website.
(collectively, the “Purposes”)
In addition, GBA LATAM may use and disclose your Personal Data for the following purposes, to:
- send you marketing communications in relation to our Research Products and Services (as applicable), any promotions in relation thereto, or the Platforms;
- send you marketing communications in relation to the Research Products and Services (as applicable) or promotions in relation thereto of business partners who provide such Research Products and Services (as applicable), including promotional mail together with your order;
- invite you to our private customer events;
- process your participation in GBA LATAM promotions, initiatives or any request for additional Personal Data such as customer surveys;
- conduct market and customer research, analysis or tracking;
- promote our products and services on GBA LATAM Platforms;
- manage the administrative and business operations of GBA LATAM and complying with internal policies and procedures;
- improve your customer experience; and
- any specific purpose in relation to a particular product or service, which we may separately notify you on the product or service page;
(collectively, the “Additional Purposes“)
We may also use your Personal Data (a) for other purposes which are reasonably related to the Purposes and where we have obtained and maintain related consent, the Additional Purposes; or (b) in circumstances where such use does not require consent under Applicable Laws.
WHO WILL YOUR PERSONAL DATA BE SHARED WITH?
In relation to our use of your Personal Data for the Purposes or Additional Purposes, we may disclose your Personal Data to GBA LATAM’s:
- employees, consultants, temporary workers;
- payment processors, who process your payment on the Website;
- professional advisers and consultants who provide legal and other advisory and consultancy services;
- agents, contractors or service providers who provide operational services to us, such as online cloud storage and processing, marketing optimization, information technology, telecommunications, security or other relevant services which requires their collection, use or disclosure of your Personal Data; and
- any other party whom you authorize us to disclose your Personal Data to.
We may also disclose your Personal Data (a) for other purposes which are reasonably related to the Purposes and where we have obtained and maintain related consent, the Additional Purposes; or (b) in circumstances where such disclosure does not require consent under the Applicable Laws.
We do our best to minimize the disclosure of your Personal Data to the information necessary to perform the related Purpose or Additional Purpose.
HOW CAN I ACCESS OR CORRECT MY PERSONAL DATA?
You may access or correct your name, e-mail address, billing addresses, contact numbers and other Personal Data by logging in to your user account on the Website under “Account Information” and clicking the “Edit” button under each relevant field.
For Personal Data that cannot be corrected by you by logging in to your user account on the Website or Apps, you may request to access and correct such Personal Data by submitting a written request to us via emailing our CONTACT US information at here. We may need to request additional information from you to confirm your identity before providing the access or making the correction.
We will do our best to respond to Personal Data access and correction requests within 30 days. Where we are unable to meet this timeline, we will update you with the soonest possible time within we can provide the information or make the correction. Please note that certain types of Personal Data access and correction requests may be exempt under Applicable Laws.
Note that we may charge you a reasonable fee for the handling and processing your Personal Data access request.
We will send your corrected Personal Data to every other person or entity to which such Personal Data was disclosed by GBA LATAM within the year before the date of the correction, unless such person or entity does not need the corrected Personal Data for any legal or business purpose or unless you and we agree that
Subject to obtaining your consent, we may send the corrected Personal Data only to specific organisations to which the Personal Data was disclosed by us within a year before the date the correction was made.
REQUEST TO WITHDRAW CONSENT
If you wish to withdraw your consent for us to send you sales, marketing or promotional information, please inform us as follows:
- to withdraw consent from promotional emails: please click on the Unsubscribe link in the promotional emails;
- to withdraw consent for any other marketing communications: please email our Data Protection Officer at the email address provided below.
Once we receive notification that you wish to withdraw your consent for receiving marketing or promotional materials or communications, it may take up to thirty (30) days for your withdrawal to be reflected in our systems. Therefore, you may still receive marketing or promotional materials or communications during this period.
You may withdraw your consent for the collection, use and/or disclosure of any of your Personal Data in our possession or under our control by submitting a written request via email to our Data Protection Officer via here. Note that, depending on the nature of the consent withdrawal, we may not be able to continue to provide you with some or all of our products or services. We will process such a request within a reasonable time from receiving notice from you of your withdrawal of consent. Once the processing is complete, we will no longer collect, use and/or disclose your Personal Data, except to the extent we retain your Personal Data for compliance, regulatory or other legal purposes.
ADMINISTRATION AND MANAGEMENT OF PERSONAL DATA
We will make reasonable efforts to ensure Personal Data likely to be used by us or disclosed by us to another organization is accurate and complete. However, you should update us of any changes in your Personal Data. We will not be responsible for relying on inaccurate or incomplete Personal Data if you have not updated us of changes.
We will also put in place reasonable security arrangements to ensure that your Personal Data is adequately protected and secured. This includes putting in place reasonable measures to prevent any unauthorized or accidental access, collection, use, disclosure, copying, modification, leakage, loss, damage, erasure, or alteration of your Personal Data. However, we will not be responsible for any unauthorized or accidental access, collection, use, disclosure, copying, modification, leakage, loss, damage, erasure, or alteration of Personal Data by third parties which is attributable to factors beyond our control.
When Personal Data in our possession is (i) no longer required for any reason connected to the purpose it was originally collected or (ii) retention by us is no longer necessary for any other legal or business purposes, we will exercise measures to ensure such Personal Data is either destroyed or anonymised.
If Personal Data is transferred out of Hong Kong SAR, we will comply with Applicable Laws in doing so. This includes: (i) obtaining your consent, unless an exception exists under Applicable Laws or any other laws, and (ii) taking reasonable steps to ascertain whether the foreign recipient of the Personal Data is bound to comply with standards of protection that are at least comparable to the Applicable Laws.
For any questions relating to your Personal Data or about this Policy, if you have a complaint regarding the collection, use or handling of your Personal Data by us, or a question about how we are complying with Applicable Laws, you may contact our Data Protection Officer via one of the following methods:
Email address: firstname.lastname@example.org
Office address: Suite 1746, 700 Nathan Road, Kowloon, Hong Kong.
Tel. +852 3960 7214 and 7215
Emails and letters should clearly state that you are making a data protection query, request or complain in the subject line to ensure the matter is dealt with expediently. We will strive to deal with any query, request or complaint promptly and fairly.
This Policy and your use of this Website shall be governed in all respects by the laws of Hong Kong SAR, and the parties hereto irrevocably submit to the non-exclusive jurisdiction of the Hong Kong SAR courts.
UPDATES ON DATA PROTECTION POLICY
As part of our efforts to ensure that we properly manage, protect and process your Personal Data, we will be reviewing our policies, procedures and processes from time to time. In this regard, GBA LATAM may update this Policy to ensure that it is consistent with industry trends and any changes in legal or regulatory requirements. We reserve the right to amend the terms of this Policy at our absolute discretion.
Subject to your rights at law, you agree to be bound by the prevailing terms of the Policy as updated from time to time on GBA LATAM Website. Any amended Policy will be posted on our website and can be viewed at https://gbalatamtradeandinvestment.com/privacy-policy. By continuing to use our Platforms and/or services after the Policy has been amended, you hereby agree to be bound by the terms of such amended Policy.
You are encouraged to visit the above Website from time to time to ensure that you are well-informed of GBA LATAM latest policies in relation to Personal Data protection.
Nothing in this Policy shall limit your rights under Applicable Laws.
The provisions of this Policy shall be severable, and if any provision, or part-provision, of this Policy shall be held or declared to be illegal, invalid, or unenforceable, such illegality, invalidity, or unenforceability shall not affect any other provision, or part-provision, of this Policy, and the remainder of this Policy, disregarding such illegal, invalid or unenforceable provision, or part-provision, shall continue in full force and effect as through such illegal, invalid, or unenforceable provision, or part-provision, had not been contained in this Policy.
The language of this Policy is English.