Effective Date: 13 December 2024
Company: Alser Limited
Registered Address: One Capital Place 7B, 18 Luard Road, Wan Chai, Hong Kong
Company Registration Number: 77464566
1. Purpose
This Confidentiality and Data Protection Policy (“Policy”) outlines Alser Limited’s (“Company”, “we”, “us”) commitment to safeguarding the confidentiality and privacy of personal and business data we collect, process, and store in the course of our operations. This Policy is designed to comply with the Personal Data (Privacy) Ordinance (PDPO) of Hong Kong and relevant international data protection standards.
2. Scope
This Policy applies to all employees, contractors, partners, and clients of Alser Limited. It governs the handling of data collected through our website (https://alserdigital.com), business activities, and communications. This includes but is not limited to:
• Personal data of employees, clients, and partners.
• Business and operational information.
• Sensitive and proprietary data related to our digital goods and services.
3. Definitions
3.1 Personal Data: Any information relating to an identified or identifiable natural person.
3.2 Confidential Information: Any non-public information, whether oral, written, or electronic, that is disclosed in connection with our business activities.
3.3 Processing: Any operation performed on data, including collection, storage, use, disclosure, and destruction.
4. Principles of Data Protection
Alser Limited adheres to the following principles when processing data:
4.1 Lawfulness, Fairness, and Transparency: Data is processed in a lawful, fair, and transparent manner.
4.2 Purpose Limitation: Data is collected for specific, explicit, and legitimate purposes and is not further processed in a manner incompatible with those purposes.
4.3 Data Minimization: Only data necessary for the purposes of processing is collected and retained.
4.4 Accuracy: Data is kept accurate and up-to-date.
4.5 Storage Limitation: Data is retained only as long as necessary for the purposes for which it was collected.
4.6 Integrity and Confidentiality: Appropriate technical and organizational measures are in place to protect data from unauthorized access, alteration, or destruction.
5. Data Collection and Use
5.1 Client Data: We collect and process client data to facilitate business transactions, including the purchase and sale of digital goods.
5.2 Employee Data: Personal data of employees is collected for human resources and payroll purposes.
5.3 Website Data: Data collected through our website may include cookies, IP addresses, and user activity to improve website functionality and user experience.
5.4 Third-Party Data: We may receive data from third parties, such as business partners and analytics providers, to enhance our services.
6. Confidentiality Obligations
6.1 Employees and Contractors: All employees and contractors are required to sign confidentiality agreements and undergo regular training on data protection practices.
6.2 Third Parties: Any third parties handling confidential information on behalf of Alser Limited are bound by contractual obligations to maintain confidentiality and comply with applicable data protection laws.
7. Security Measures
7.1 Technical Measures: We employ industry-standard encryption, firewalls, and secure data storage systems to protect sensitive information.
7.2 Organizational Measures: Access to data is restricted to authorized personnel only, and regular audits are conducted to ensure compliance with security protocols.
7.3 Incident Response: In the event of a data breach, we will notify affected parties and relevant authorities promptly, as required by law.
8. Data Subject Rights
Individuals have the following rights under this Policy:
• Access: To request access to their personal data.
• Correction: To request corrections to inaccurate or incomplete data.
• Erasure: To request the deletion of their personal data under specific circumstances.
• Restriction: To request the restriction of data processing in certain cases.
• Objection: To object to the processing of their data for legitimate reasons.
Requests can be submitted by contacting us at [info@alserdigital.com].
9. Data Retention
We retain personal and business data only for as long as necessary to fulfill the purposes for which it was collected or as required by applicable laws and regulations.
10. International Data Transfers
Alser Limited operates globally. Data may be transferred to and processed in countries outside Hong Kong, subject to appropriate safeguards to ensure data protection compliance.
11. Monitoring and Compliance
11.1 Compliance Officer: Alser Limited has appointed a Data Protection Officer (DPO) responsible for overseeing compliance with this Policy and applicable laws.
11.2 Audits: Regular internal and external audits are conducted to ensure adherence to data protection standards.
12. Policy Updates
This Policy is reviewed annually or whenever there are significant changes in applicable laws, regulations, or business practices. Updates will be posted on our website with an updated “Effective Date.”
13. Contact Information
For questions, concerns, or requests related to this Policy, please contact us:
Email: info@alserdigital.com
Address: One Capital Place 7B, 18 Luard Road, Wan Chai, Hong Kong
