PRIVACY POLICY

We, Lavoropiu Hong Kong Limited, as Data Controller and according to the Hong Kong Personal Data (Privacy) Ordinance (“PDPO”), provides you, as the Data Subject the following information.

Types of personal data

“Personal data” refers to any data which directly or indirectly identifies you as an individual, or is capable of doing so. We collect and use personal data that is necessary for the performance of our contract with you or in order to take steps at your request prior to entering into a contract or to generally conduct business with you.

When you visit our website, we will collect browsing data (see section on “Browsing data” below).

When you engage in our services, we will have to collect further personal data from you, which may include, but is not limited to:

• Contact information such as your name, email address, mailing address, and telephone number;
• Demographic information such as age, gender, citizenship and residency information, date of birth, marital status; and
• Information typically found in a Curriculum Vitae or resume such as education background, qualification and experiences, and employment history.

Browsing data

The functioning of the website itself necessarily requires the processing of browsing data.

This is anonymous information, which is collected to allow the site to function correctly, is not associated with specifically identified subjects, is used for the sole purpose of obtaining anonymous statistical information on its use, and checking its regular operation, and is automatically deleted immediately after their processing.

Browsing data includes IP addresses or domain names of computers used by users connecting to the site, URI (Uniform Resource Identifier) addresses of requested resources, the time of the request, the method used to submit it to the server, the size of the file obtained in response, the numerical code indicating the status of the answer given by the server and other parameters relating to the operating system and the user’s IT environment.

Such information could become personal data, but only when further and subsequent processing activities occur before their erasure.

The browsing data will only be further processed according to applicable laws.

Data Collection and Contact Forms

The personal data of the Data Subject are provided freely and therefore collected directly from you, through the following means:

• compilation of website forms;
• provided when you first engage our services; and
• when you communicate or correspond with us (e.g. by phone, email or otherwise).

The personal data provided may be processed for purposes directly related to the provision of the requested service. The condition of the data necessary for these purposes is optional. In the fields marked as indispensable, any refusal to provide them makes it impossible to supply the requested service. Please note that if you do not provide us with the personal data requested, we may not be able to provide the full range of our services to you.

We will only use your personal data with your consent or as otherwise permitted under applicable laws and regulations, and we will attempt to ensure that the personal data is both accurate and kept up to date.

Purposes for which we will use your personal data

We may use the personal information collected for the following purposes:

• process employment application, recruitment and provide job matching services;
• communicate with you via telephone, mail, e-mail, facsimile or any other means of communication;
• conduct market research for statistical or other purposes and designing services for clients;
• provide you with alerts, updates, materials, information or other types of information that you requested or signed up to;
• make disclosure as required by any applicable law, rules, regulations, codes of practice or guidelines or to assist in law enforcement purposes, investigations by police or other government or regulatory authorities in Hong Kong or elsewhere;
• comply with the laws of any applicable jurisdiction and with any applicable internal policies of our group company;
• carry out other services in connection with our business; and
• other purposes directly relating to any of the above.

Processing Means

The following paragraph illustrates how and for how long the Data Subjects’ personal data will be processed.

Concerning the indicated purposes, the processing of personal data is carried out using manual (as on paper), IT, and telematic tools, according to logic strictly related to the purposes themselves and in any case, with devices capable of guaranteeing the security and confidentiality of the data.

The processing is taken by authorized persons to carry out these tasks, always identified, appropriately prepared and trained on legal obligations, and adopt the most suitable security measures in the state to avoid accidental loss and accidental destruction, illicit or incorrect use, unauthorized access.

Personal data processing implies the knowledge of the same by those authorized persons to process them (for example, IT systems, administrative, marketing, communication, and logistics office workers).

We have stringent collection, storage and processing practices in place to ensure the security and confidentiality of your personal data and to guard against the unauthorised access, processing, use or loss and theft of your personal data. We also take steps to procure that third parties to whom we transfer your data also have similar security processes in place to ensure the security and confidentiality of your personal data, and compliance with any applicable data privacy laws.

Please note, however, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk.

Disclosure and Transfer of Personal Data

We will keep your personal data confidential but, subject to any applicable law, we may disclose your personal data for the above purposes to the following classes of transferees:

• our clients who have been matched as your prospective employers;
• any agent, business partner, adviser, auditor, contractor, financial institution, and third-party service provider who provides administrative, data processing, data storage, communications, computer, payment, system infrastructure and operation, website administration, or any other service which assist us to carry out the purposes outlined above;
• our legal and professional advisors; or
• government or regulatory bodies or any person to whom we are required to make disclosure under applicable laws and regulations in or outside of Hong Kong.

In connection with the purposes outlined above, the personal data that we collect from you may be transferred to, and stored at, a destination outside Hong Kong. It may also be processed by persons referred to above who operate outside Hong Kong.

By submitting your personal data you agree to this transfer, storing or processing of data outside Hong Kong, where there may not be in place data protection laws which are substantially similar to, or serve the same purposes as, the data protection laws and regulations in Hong Kong. However, we will take all steps reasonably necessary to ensure that your data is treated securely in accordance with this privacy policy.

Personal data will be kept until the Data Subject requests their erasure or the termination of all the purposes for which they are processed.

Third-party sites

Our website or our communication with you may from time to time contain links to third-party websites over which we have no control. If you follow a link to any of these websites, please note that they have their own practices and policies. We encourage you to read the privacy policies or statements of these websites in order to understand your rights. We accept no responsibility or liability for any practices of third-party websites.

Contact Details

The Data Controller is Lavoropiu Hong Kong Limited (Company no. 1860697), with registered office at Room 1, 2/F., Casey Building, 38 Lok Ku Road, Sheung Wan, Hong Kong.

The rights indicated below may be exercised by contacting the Data Controller as the postal address indicated above or using the e-mail privacy@pyou.com.hk.

Right of access to personal data and other rights of interested parties

In the cases provided for, you have the right:

• to check whether we hold personal data about you;
• to obtain access to personal data we hold about you;
• to correct any inaccuracy or error in any personal data we hold about you;
• – to obtain the restriction of the processing that concerns you; and
• – to object the processing, in the case provided by the law

Data subjects who believe that the processing of their personal data has been carried out through this website breaching current data protection legal framework may lodge a complaint to our Data Protection Officer.

Changes to our Privacy Policy

We may amend this Privacy Policy from time to time by posting the updated Policy on our website. By continuing to use our services after the changes come into effect means that you agree to be bound by the revised Policy.