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Privacy Policy

Privacy Policy Statement

October 2020

  1. INTRODUCTION

Your Privacy Matters

This Privacy Policy Statement (“Statement”) applies when you use our Services (described below). We offer our users choices about the data we collect, use and share as described in this Statement.

Our registered users (“Members”) share their professional identities, engage with their network, exchange knowledge and professional insights, post and view relevant content, learn and find business and career opportunities. Content and data on some of our Services is viewable to non-Members (“Visitors”).

Services

This Statement applies to lawyeraccountant.com and other lawyeraccoutant.com-related websites, communications and services (“Services”).

This Statement is adopted as the Privacy Policy Statement of Dual Professional Media Limited (“DPML”). The purpose of this Statement is to establish the policies and practices of DPML’s commitment to protect the privacy of personal data and to act in compliance with the provisions of the Hong Kong Personal Data (Privacy) Ordinance (Cap. 486) (the “Ordinance”).

Change

DPML (“we” or “us”) can modify this Statement, and if we make material changes to it, we will provide notice through our Services, or by other means, to provide you the opportunity to review the changes before they become effective. If you object to any changes, you may close your account.

You acknowledge that your continued use of our Services after we publish or send a notice about our changes to this Statement means that the collection, use and sharing of your personal data is subject to the updated Statement.

  1. KINDS OF PERSONAL DATA HELD BY DPML

2.1. There are two broad categories of personal data held in DPML. They are personal data related to (i) Members or Visitors and (ii) potential employees of DPML.

2.2. Personal data held by DPML regarding Members or Visitors may include the following:

  • name and address, e-mail address, password, occupation and contact details;
  • information on Member’s profile, such as bar admission, accounting designation, work experience, skills, photo, city or area and endorsements
  • current employer or business and nature of position and;
  • information obtained by DPML in the ordinary course of the continuation of the business relationship (for example, if you register for a Premium or LawyerAccountantMarketing service, you will need to provide payment (e.g., credit card) and billing information);

 2.3. Personal data relating to employment held by DPML may include the following:

  • name and address, contact details, date of birth and nationality of potential employees and their spouses and their identity card and/or passport numbers and place and date of issue thereof;
  • additional information compiled about potential employees to assess their suitability for a job in the course of the recruitment selection process which may include references obtained from their current or former employers or other sources;
  • additional information compiled about potential employees which may include records of remuneration and benefits paid to the potential employees, records of job postings, transfer and training, records of medical checks, sick leave and other medical claims and performance appraisal reports of the potential employees;
  • information which is in the public domain, if required.

2.4. DPML may hold other kinds of personal data which it needs in the light of experience and the specific nature of its business.

  1. PURPOSES THE PERSONAL DATA ARE HELD

3.1. It is necessary for Members to supply DPML with data in connection with the opening or continuation of membership accounts.

3.2. It is also the case that data are collected from Members or Visitors in the ordinary course of the continuation of the membership relationship.

3.3. How we use your personal data will depend on which Services you use, how you use those Services and the choices you make in your Membership settings. We use the data that we have about you to provide and personalize, including with the help of automated systems and inferences we make, our Services (including ads) so that they can be more relevant and useful to you and others.

The purposes for which data relating to a customer may be used are as follows:

3.3.1. Services

Our Services help you connect with others, find and be found for work and business opportunities and stay informed.

Membership

Our Services allow you to find and be found for work and business opportunities and stay in touch and up to date with colleagues, partners, clients, and other professional contacts.

We will use data about you (such as your profile) to help others find your profile. You can also opt-in to allow us to use your precise location or proximity to others for certain tasks.

Stay Informed

Our Services allow you to stay informed about news, events and ideas regarding professional topics you care about, and from other dually-qualified professionals. We use your content, activity and other data, including your name and picture, to provide notices to your network and others.

Career

Our Services allow you to explore careers, and seek out, and be found for, career opportunities. Your profile can be found by those looking to hire (for a job or a specific task) or be hired by you. You can signal that you are interested in changing jobs and with your permission, we may share information with job recruiters. We will use your data to recommend jobs to you and you to recruiters. Keeping your profile accurate and up-to-date may help you better connect to others and to opportunities through our Services.

Productivity

Our Services allow you to collaborate with colleagues, search for potential clients, customers, partners and others to do business with. Our Services allow you to communicate with other Members.

3.3.2. Communications

We will contact you through email, mobile phone, notices posted on our websites or apps, messages to your LawyerAccountant inbox, and other ways through our Services, including text messages and push notifications. We will send you messages about the availability of our Services, security, or other service-related issues. We also send messages about how to use the Services, network updates, reminders, job suggestions and promotional messages from us and our partners. You may change your communication preferences at any time. Please be aware that you cannot opt-out of receiving service messages from us, including security and legal notices.

3.3.3. Advertising

We target (and measure the performance of) ads to Members, Visitors and others both on and off our Services directly or through a variety of partners, using the following data, whether separately or combined:

  • Data from advertising technologies on and off our Services, like web beacons, pixels, ad tags, cookies, and device identifiers;
  • Member-provided information (e.g., profile, contact information, title, bar admission, accounting designation, skills and industry);
  • Data from your use of our Services (e.g., search history, feed, content you read, page visits, videos you watch, clicking on an ad, etc.);
  • Information from advertising partners and publishers; and
  • Information inferred from data described above.

We will show you ads called sponsored content which look similar to non-sponsored content, except that they are labelled “ads” or “sponsored.” If you take an action (such as like, comment or share) on these ads, your action is associated with your name and viewable by others, including the advertiser.

Ad Choices

We adhere to self-regulatory principles for interest-based advertising and participate in industry opt-outs from such ads. This does not opt you out of receiving advertising; you will continue to get other ads by advertisers not listed with these self-regulatory tools.

Info to Ad Providers

We do not share your personal data with any third-party advertisers or ad networks for their advertising except for: (i) hashed or device identifiers (to the extent they are personal data in some countries); (ii) with your separate permission (e.g., lead generation form) or (iii) data already visible to any users of the Services (e.g. profile). However, if you view or click on an ad on or off our site, the ad provider will get a signal that someone visited the page that displayed the ad, and they may through the use of mechanisms such as cookies determine it is you. Advertising partners can associate personal data collected by the advertiser directly from you with our cookies and similar technologies. In such instances, we seek to contractually require such advertising partners to obtain your explicit, opt-in consent before doing so.

3.3.4. Marketing

We use data and content about Members for invitations and communications promoting membership and network growth, engagement and our Services.

3.3.5. Developing Services and Research

Service Development

We use data, including public feedback, to conduct research and development for the further development of our Services in order to provide you and others with a better, more intuitive and personalized experience, drive membership growth and engagement on our Services, and help connect professionals to each other and to economic opportunity.

Surveys

Polls and surveys may be conducted by us and others through our Services. You are not obligated to respond to polls or surveys, and you have choices about the information you provide.

3.3.6. Customer Support

We use the data (which can include your communications) to investigate, respond to and resolve complaints and Service issues (e.g., bugs).

3.3.7. Aggregate Insights

We use your data to produce and share aggregated insights that do not identify you. For example we may use your data to generate statistics about our members, their main industry, to calculate ad impressions served or clicked on, or to publish visitor demographics for a Service or demographic workforce insights.

3.3.8. Security and Investigations

We use your data (including your communications) if we think it’s necessary for security purposes or to investigate possible fraud or other violations of this Statement and/or attempts to harm our Members or Visitors.

3.4. The purposes for which data relating to potential employees may be used are as follows:

  • processing employment applications;
  • determining and reviewing salaries, bonuses and other benefits;
  • consideration for promotion, training or transfer;
  • monitoring compliance with internal rules of DPML;
  • meeting the requirements to make disclosure under the requirements of any law binding on DPML or under and for the purposes of any guidelines issued by regulatory or other authorities with which DPML are expected to comply; and
  • purposes relating thereto.
  1. SECURITY OF PERSONAL DATA

It is the policy of DPML to ensure an appropriate level of protection for personal data in order to prevent unauthorised or accidental access, processing, erasure or other use of that data, commensurate with the sensitivity of the data and the harm that would be caused by occurrence of any of the aforesaid events. It is the practice of DPML to achieve appropriate levels of security protection by restricting physical access to data by providing secure storage facilities, and incorporating security measures into equipment in which data is held. Measures are taken to ensure the integrity, prudence, and competence of persons having access to personal data. Data is only transmitted by secure means to prevent unauthorized or accidental access. If a data user engages a data processor (whether within or outside Hong Kong Special Administrative Region) to process personal data on data user’s behalf, the data user must adopt contractual or other means to prevent unauthorized or accidental access, processing, erasure, loss or use of the data transferred to the data processor for processing.

  1. ACCURACY OF PERSONAL DATA

It is the policy of DPML to ensure accuracy of all personal data collected and processed by DPML. Appropriate procedures are implemented to provide for all personal data to be regularly checked and updated to ensure that it is reasonably accurate having regard to the purposes for which that data is used. In so far as personal data held by DPML consists of statements of opinion, all reasonably practicable steps are taken to ensure that any facts cited in support of such statements of opinion are correct. If a data user engages a data processor (whether within or outside Hong Kong) to process personal data on data user’s behalf, the data user must adopt contractual or other means to prevent any personal data transferred to the data processor from being kept longer than is necessary for processing of the data.

  1. COLLECTION OF PERSONAL DATA

6.1. In the course of collecting personal data, DPML will provide the individuals concerned with a Personal Data (Privacy) Ordinance Notice informing them of the purpose of collection, classes of persons to whom the data may be transferred, their rights to access and correct the data, and other relevant information.

6.2.  Prior to collect and obtain any personal data from public domain, DPML will observe the original purposes of making the personal data available in the public domain (such as the purpose of establishing the public register in the enabling legislation) and the restrictions, if any, imposed by the original data users on further users.

6.3. In relation to the collection of personal data on-line, the following practices are adopted:

On-line Security

DPML will follow strict standards of security and confidentiality to protect any information provided to DPML online. Encryption technology is employed for sensitive data transmission on the Internet to protect individuals’ privacy.

On-line Correction

Personal data provided to DPML through an on-line facility, once submitted, may not be facilitated to be deleted, corrected or updated on-line. If deletion, correction and updates are not allowed online, users should approach relevant members of DPML.

On-line Retention

Personal data collected on-line will be transferred to DPML for processing. Personal data will be retained in DPML’s internet systems’ database normally for a period of not longer than 8 years.

It has to be mentioned that no personal data (i.e. name, mobile number or personal email address) collection via on-line is shared with any third party vendor.

6.4. Data We Collect

6.4.1. Data You Provide To Us

Registration

To create an account you need to provide data including your name, a username, email address, and a password.

If you register for a Premium or LawyerAccountantMarketing Service, you will need to provide payment (e.g., credit card) and billing information.

Profile

You have choices about the information on your profile, such as your bar admission, accounting designation, work experience, skills, photo, city or area and endorsements. You don’t have to provide additional information on your profile; however, profile information helps you to get more from our Services, including helping business opportunities find you. It’s your choice whether to include sensitive information on your profile and to make that sensitive information public. Please do not post or add personal data to your profile that you would not want to be publicly available.

Posting and Uploading

We collect personal data from you when you provide, post or upload it to our Services, such as when you fill out a form (e.g., with demographic data).

You don’t have to post or upload personal data; though if you don’t, it may limit your ability to grow and engage with your network over our Services.

6.4.2. Data From Others

Content and News

You and others may post content that includes information about you (as part of articles, posts, comments, videos) on our Services. We collect public information about you, such as professional-related news and accomplishments (e.g., professional recognition, conference speakers, projects, deals, etc.) and make it available as part of our Services (e.g. suggestions for your profile, or notifications of mentions in the news or blog).

Partners

We may receive personal data about you when you use the services of our customers and partners, such as prospective employers.

Related Companies and Other Services

We receive data about you when you use some of the other services provided by us or our affiliates.

6.4.3. Service Use

We log usage data when you visit or otherwise use our Services, including our sites, such as when you view or click on content or ads (on or off our sites), or perform a search. We use log-ins, cookies, device information and internet protocol (“IP”) addresses to identify you and log your use.

6.4.4. Cookies, Web Beacons and Other Similar Technologies

Cookies are small pieces of data transmitted from a web server to a web browser. Cookie data is stored on a local hard drive such that the web server can later read back the cookie data from a web browser. This is useful for allowing a website to maintain information on a particular user.

Cookies are designed to be read only by the website that provides them. Cookies cannot be used to obtain data from a user’s hard drive, get a user’s email address or gather a user’s sensitive information.

We use cookies and similar technologies (e.g., web beacons, pixels, ad tags and device identifiers) to recognize you and/or your device(s) on, off and across different Services and devices. You can control cookies through your browser settings and other tools, but doing so may affect your ability to access certain Services.

DPML will not store user’s sensitive information in cookies. Once a session is established, all the communications will use the cookies to identify a user.

6.4.5. Analytical Tracking

Users’ visit to DPML’s websites will be recorded for analysis and information may be collected through technologies such as cookies, tags and web logs etc. The information collected is anonymous research data and no personally identifiable information is collected. DPML mainly collects the information to understand more about our users including user demographics, interests and usage patterns.

DPML also uses Google Analytics to collect information on how Members and Visitors use our website. The cookies collect information in an anonymous form, including the number of visitors to the website, how visitors were directed to the website, and the pages they have visited.

6.4.6. Your Device and Location

When you visit or leave our Services (including our plugins or cookies or similar technology on the sites of others), we get information about your IP address, proxy server, operating system, web browser and add-ons, device identifier and features, and/or ISP or your mobile carrier. If you use our Services from a mobile device, that device will send us data about your location based on your phone settings.

6.4.7. Messages

We collect information about you when you send, receive, or engage with messages in connection with our Services.

6.4.8. Other

Our Services are dynamic, and we often introduce new features, which may require the collection of

new information. If we collect materially different personal data or materially change how we use your data, we will notify you and may also modify this Statement.

  1. How We Share Information

7.1. Our Services

Profile

Your profile is fully visible to all Members and customers of our Services. It is also fully visible to others on or off of our Services (e.g., Visitors to our Services or users of third- party search engines). As detailed in our Terms & Conditions, your type of subscription impacts the availability of your profile and whether they can view certain fields in your profile.

Posts, Likes, Comments, Messages

Our Services allow viewing and sharing information including through posts, likes, and comments.

When you share a post (e.g., an update, image, video or article) publicly it can be viewed by everyone. Members, Visitors and others will be able to find and see your publicly-shared content, including your name and photo if you have provided one.

Any information you share through companies’ or other organizations’ pages on our Services will be viewable by it and others who visit those pages.

When you like or comment on another’s content (including ads), others will be able to view these “social actions” and associate it with you (e.g., your name, profile and photo if you provided it).

7.2. Communication Archival

We do not provide archival services of communications and social media activity beyond the built-in capabilities available via our Services.

7.3. Others’ Services

Excerpts from your profile may appear on the services of others (e.g., search engine results, social media aggregators, talent and lead managers). “Old” profile information remains on these services until they update their data cache with changes you made to your profile.

7.4. Related Services

We will share your personal data with our affiliates to provide and develop our Services. We may combine information internally across the different Services covered by this Statement to help our Services be more relevant and useful to you and others.

7.5. Service Providers

We use others to help us provide our Services (e.g., maintenance, analysis, audit, payments, fraud detection, marketing and development). They will have access to your information as reasonably necessary to perform these tasks on our behalf and are obligated not to disclose or use it for other purposes.

7.6. Legal Disclosures

It is possible that we will need to disclose information about you when required by law, subpoena, or other legal process or if we have a good faith belief that disclosure is reasonably necessary to (1) investigate, prevent, or take action regarding suspected or actual illegal activities or to assist government enforcement agencies; (2) enforce our agreements with you, (3) investigate and defend ourselves against any third-party claims or allegations, (4) protect the security or integrity of our Service (such as by sharing with companies facing similar threats); or (5) exercise or protect the rights and safety of DPML, our Members, personnel, or others. We attempt to notify Members about legal demands for their personal data when appropriate in our judgment, unless prohibited by law or court order or when the request is an emergency. We may dispute such demands when we believe, in our discretion, that the requests are overbroad, vague or lack proper authority, but we do not promise to challenge every demand.

7.7. Change in Control or Sale

We can also share your personal data as part of a sale, merger or change in control, or in preparation for any of these events. Any other entity which buys us or part of our business will have the right to continue to use your data, but only in the manner set out in this Statement unless you agree otherwise.

  1. DATA ACCESS REQUESTS AND DATA CORRECTION REQUESTS

8.1. Your Choices & Obligations

8.1.1. Data Retention

We retain your personal data while your account is in existence or as needed to provide you Services. This includes data you or others provided to us and data generated or inferred from your use of our Services. We will retain your information and keep your profile open until you decide to close your account.

8.1.2. Rights to Access and Control Your Personal Data

We provide choices about the collection, use and sharing of your data, from deleting or correcting data you include in your profile.

For personal data that we have about you:

  • Delete Data: You can ask us to erase or delete all or some of your personal data (e.g., if it is no longer necessary to provide Services to you).
  • Change or Correct Data: You can edit some of your personal data through your account. You can also ask us to change, update or fix your data in certain cases, particularly if it’s inaccurate.
  • Object to, or Limit or Restrict, Use of Data: You can ask us to stop using all or some of your personal data (e.g., if we have no legal right to keep using it) or to limit our use of it (e.g., if your personal data is inaccurate or unlawfully held).
  • Right to Access and/or Take Your Data: You can ask us for a copy of your personal data and can ask for a copy of personal data you provided in machine readable form.

8.1.3. Account Closure

If you choose to close your Lawyer Accountant account, your personal data will generally stop being visible to others on our Services within 24 hours. We generally delete closed account information within 30 days of account closure, except as noted below.

We retain your personal data even after you have closed your account if reasonably necessary to comply with our legal obligations (including law enforcement requests), meet regulatory requirements, resolve disputes, maintain security, prevent fraud and abuse, or fulfill your request to “unsubscribe” from further messages from us. We will retain de-personalized information after your account has been closed.

Information you have shared with others (e.g., through messages, updates or group posts) will remain visible after you closed your account or deleted the information from your own profile or mailbox, and we do not control data that other Members copied out of our Services. Groups content and ratings or review content associated with closed accounts will show an unknown user as the source. Your profile may continue to be displayed in the services of others (e.g., search engine results) until they refresh their cache.

8.2.  It is the policy of DPML to comply with and process all data access and correction requests in accordance with the provisions of the Ordinance, and for all staff concerned to be familiar with the requirements for assisting individuals to make such requests.

8.3.  DPML may, subject to the Ordinance and the guidelines thereon issued by the Privacy Commissioner for Personal Data (“Privacy Commissioner”), impose a fee for complying with a data access request (“DAR”). DPML is only allowed to charge a DAR requestor for the costs which are directly related to and necessary for complying with a DAR. If a person making a data access request requires an additional copy of the personal data that DPML has previously supplied pursuant to an earlier data access request, DPML may charge a fee to cover the full administrative and other costs incurred in supplying that additional copy.

8.4. Data access and correction requests to DPML may be addressed to DPML’s Board of Directors or other person as specifically advised.

  1. RETENTION OF PERSONAL DATA

DPML shall usually hold data relating to the customer(s) for a period of at least eight years after the business relationship is ended or such other period as prescribed by applicable laws and regulation after closure of account/termination of service.

  1. CONTACT DETAILS

10.1. The Board of Directors of DPML will designate an individual to co-ordinate and oversee compliance with the Ordinance and the personal data protection policies of DPML.

10.2. The contact details of such designated person are as follows:

Name: Jean-Frederic Gagne
Title: Director
Address: 1002 Unicorn Trade Centre

127-131 Des Voeux Road

Central

Hong Kong

E-mail: info@dualprofessional.com