This Privacy Policy describes the policies and practices of Reach Networks Hong Kong Limited and its affiliates ("REACH", "we", "our" or "us") in relation to the privacy of your personal data which is collected, held, processed and used by REACH.

"Personal data" means any personally identifying information.

"You" and "Your" when used in this Privacy Policy Statement include any person who accesses the REACH web site and submits personal data.

REACH respects the privacy of your personal data. REACH pledges to meet fully, and where possible exceed, internationally recognised standards of personal data privacy protection and comply with the Personal Data (Privacy) Ordinance 1995 (Cap 486) (the "Ordinance") when processing personal data collected in Hong Kong. REACH shall ensure compliance by our staff with the strictest standards of security and confidentiality.

These policies and practices may be amended from time to time. You should check our Privacy Policy Statement regularly to ensure you are aware of your latest policies.

2. TYPES OF INFORMATION COLLECTED

Information about you is collected in the following ways:

(a) Anonymous Access

If you visit our web site but do not submit any personal data on-line, then we may record your visit as a "hit" even though we will not collect any personally identifiable information from you. In addition, we may make a record of your visit that shows only the domain name server address part of your email address (e.g. "reach.com" from an e- mail address of "jchan@reach.com"), and of the pages visited. This information is used by us to produce aggregated information about the number and types of visitors to the REACH web site by reference to their Domain Name Server address. This information is used by us only for preparing general statistics on the usage of our web site.

(b) Submission of personal data

When you make an enquiry with REACH via email to us, you may include in your email various items of personal data such as your name and your email address.

We may use data collected from you for the purpose of responding to your enquiries and subsequent communications to you which are related to your initial enquiry. We may further communicate with you for the purpose of conducting a market survey and we will provide you with a separate privacy protection policy in relation to that market survey. Upon your request to us, you will be able to access and/or correct your personal data. Please refer to paragraph 7 below for details on how you may obtain and correct any personal data relating to you which we may hold.

(c) Cookies

Some areas of the REACH web site may use "cookies" to identify you. A cookie is a small amount of data that is sent to your computer from a web server and stored on your computer's hard drive.

REACH may, for the purposes set out in paragraph 2 above, share data it has collected with the following: (i) any company in the REACH group, (ii) any person to whom REACH is under a legal or regulatory obligation to make disclosure and (iii) any person who is under a duty of confidentiality to REACH.

4. ACCURACY OF PERSONAL DATA

Whilst we do not provide on-line access to and correction of personal data held by REACH, we fully comply with the rights of access and correction obligations of the Ordinance. Please refer to paragraph 7 below for details on how you can obtain and correct any personal data relating to you that we may hold.

5. RETENTION OF PERSONAL DATA

We shall retain your personal data for as long as is necessary for the purposes of responding to your email enquiries and subsequent communications to you which are related to your initial enquiry. If you object to our retention of your personal data, you may request the destruction of the data by writing to us at the address in paragraph 8 below unless the personal data is retained to satisfy any applicable statutory or contractual obligations.

6. SECURITY OF PERSONAL DATA

(a) Information Security

Given the nature of the internet, we cannot guarantee that the transmission of personal data is 100% secure. However, we shall take all practicable steps to ensure that any personal data collected by us via the REACH web site is safe and secure from third party interference.

(b) Employee Access

In general, our business practices limit employee access to confidential personal data, and limit the use and disclosure of such information to authorised persons, processes and transactions. We are committed to take all reasonably practicable measures to ensure that staff handling employment-related personal data are trained and instructed to do so according to the privacy policy of REACH, will exercise due diligence in the application of this policy and are subject to procedures designed to ensure compliance with this policy.

7. RIGHTS OF ACCESS AND CORRECTION

Under the Ordinance, individuals have the right (subject to certain exemptions) to:

(a) check whether REACH holds any personal data relating to them and request access to such personal data; and

(b) require REACH to correct any personal data relating to them which is inaccurate.

Requests for access to or correction of personal data should be addressed to REACH's Data Privacy Officer at the address listed in paragraph 8 below.

REACH prefers to receive data access and correction requests by post. When submitting a data access or correction request, please provide REACH with documentary proof of identity (e.g. a copy of your Hong Kong Identity Card or Passport). We need proof of your identity so we do not release your personal data to unauthorised persons. REACH charges a fee of HK$100 for data access requests. No fee is charged for data correction requests.

8. FURTHER INFORMATION

If you have any queries about our Privacy Policy and practices, please contact:

Martin Stone
General Counsel
Reach Networks Hong Kong Limited
6th Floor, Hermes House,
10 Middle Road Road
Tsim Sha Tsui
Hong Kong

Telephone: +852 2983 3688
Fax: +852 2824 0518
Email: Martin.Stone@REACH.com