Effective as of 1 April 2019
ONE Pacific Limited is committed to protecting the privacy of individuals who visit and interact with their web sites (which we refer to as “Visitors” in this document) and of persons who are recipients of the Services, as this term is defined below (which we refer to as “Customers” in this document). This Privacy Statement and Policy (in short, the “Policy”) describes ONE Pac’ privacy practices in relation to the use of its web sites, the performance or delivery of Services to Customers and other interactions with people that are not Visitors or Customers.
Scope of this Policy
This Policy applies to the information we obtain or collect through our performance or delivery of Services to our Customers or when people otherwise interact or communicate with us either directly or through our web sites.
Here are some definitions of terms used throughout this Policy:
The “ONE Pac Websites” include our web sites, such as www.onepac.net (including the related sub-domains and pages).
The “Services” are the professional services we provide to our Customers.
A “Device” is any computer used to access the ONE Pac Websites, including without limitation a desktop, laptop, smartphone, tablet, or other consumer electronic device.
Type of Information Collected
The term “Personal Information” refers to personal information that we may collect from your use of the ONE Pac Websites and third party social media platforms as well as your interactions with us offline such as through our performance of Services for a Customer or other various communications of a commercial nature such as newsletters, announcements and the like. Personal information is information that identifies an individual or relates to an identifiable person. Examples of Personal Information include information provided by:
- a Customer representative about herself, including her name, job title, e-mail and physical address, work telephone number, mobile phone number, billing information, company affiliation and associated interests. ONE Pac may also collect other information about the Customer and some employees, for example through the ONE Pac Websites, as part of that interaction;
- an employee at a prospect customer about herself including her name, job title, e-mail and physical address, , work telephone number, mobile phone number, billing information, company affiliation and associated interests. ONE Pac may also collect other information about the prospect customer and some employees, for example through the ONE Pac Websites, and third party social media platform as part of that interaction; or
- We may also collect other information through your interaction with and use of the ONE Pac Websites and third party social media platforms as well as your interactions with us offline, which does not reveal your specific identity or does not directly relate to you. Such other information may include, but is not limited to, Personal Information that you have shared with third party social media platform operators (e.g. account login name, profile picture, contact details), browser and Device information, data collected through automated electronic interactions, application usage data, demographic information, geographic or geo-location information, statistical and aggregated information. Statistical or aggregated information does not directly identify a specific person, but it may be derived from Personal Information. For example, we may aggregate Personal Information to calculate the percentage of Customers in a particular postal or zip code.
How ONE Pac Collects Personal Information
ONE Pac and our third party service providers may collect Personal Information and other information from a variety of sources that generally fall into three categories:
- Direct Interactions: From your use of and interaction with us through the ONE Pac Websites and other activities such as submission of registrations and forms, or sales inquiries and transactions as well as in-person meetings in trade shows or other similar events.
- Publicly Available Data / Data from Third Parties: Other data you may have made publicly available, such as social media posts and social media profile information, or data provided by third party sources, such as marketing opt-in lists, or data aggregators.
- Automated Interactions with Devices: From the use of technologies such as electronic communication protocols, cookies, embedded URLs or pixels, or widgets, buttons and tools.
Although ONE Pac’ use of Automated Interactions may change over time as technology evolves, the following descriptions are designed to provide you with additional detail about ONE Pac’ current approach to information collected from Automated Interactions.
Electronic Communications Protocols: As is the case when you visit most websites and use most apps, ONE Pac may automatically receive information from you as part of the communication connection itself, which often consists of network routing information (where you came from), equipment information (browser type), your IP address (which may identify your general geographic location or company), and date and time.
ONE Pac may also automatically receive and record information about your interaction with the ONE Pac Websites, such as clickstream information (when each ONE Pac webpage was visited and how much time was spent on the page), or general geo-location data.
Cookies: ONE Pac’ servers will query your browser to see if there are “cookies” previously set by the ONE Pac Websites. A cookie is a small piece of information sent by a web server to store on a web browser so it can later be read back from that browser. Cookies may collect information, including a unique identifier, user preferences, profile information, membership information, and general usage and volume statistical information. Cookies may also be used to collect individualized web site use data, provide electronic web site personalization, or conduct and measure the effectiveness of advertising in accordance with this Policy. Some cookies may remain on users’ computers after they leave the ONE Pac Websites. While the majority are set to expire within 1-24 months of your last visit to the website that set the cookie, others may not expire because of their nature, like cookies that remember opt-out preferences.
Your browser may provide you with information and control over cookies. You can set your browser to alert you when a cookie is being used, and accept or reject the cookie. You can also set your browser to refuse all cookies or accept only cookies returned to the originating servers. Users can generally disable the cookie feature on their browser without affecting their ability to use the site, except in some cases where cookies are used as an essential security feature necessary for transaction completion. Cookies, however, are important to the proper functioning of a site, and disabling them may degrade your experience and interfere with website features and customizations.
Web Beacons and Embedded Pixels and Similar Technologies: On the ONE Pac Websites, ONE Pac and its service providers may use web beacons and embedded pixel technologies for the purposes of identifying unique user visits (as opposed to aggregate hits), and for advertising purposes. In addition, web beacons and embedded pixels or other technologies may be used in e-mails and our online display advertising to provide information on when the e-mail or ad was opened to track marketing campaign responsiveness; information collected using these technologies may be associated with the recipient’s e-mail address.
Physical Location: We may collect the physical location of your device and use it to provide you with personalized location-based services or content. In some instances, you may be permitted to allow or deny such use of your device’s location, but if you choose to deny such use, we may not be able to provide you with the applicable personalized services or content.
How ONE Pac Uses Personal Information Collected
ONE Pac uses and shares the Personal Information it collects (unless directed otherwise by applicable law), to:
- Engage in Business Relationship. ONE Pac may use Personal Information to engage in a business relationship with you.
- Engage in Employment-related Exchanges. ONE Pac may use Personal Information to engage in exchanges leading to a possible employment relationship with ONE Pac.
- Provide Support or Other Services. ONE Pac may use your Personal Information to provide you support or other Services you have ordered.
- Improve Quality and Facilitate Use of the ONE Pac Websites. ONE Pac may use your Personal Information to help create and personalize content on the ONE Pac Websites and third party social media platforms, facilitate your use of the ONE Pac Websites, improve relevance and quality, track marketing campaign effectiveness (including online advertising and e-mail marketing), and evaluate campaign response rates with third party marketing analytics and digital experience platforms.
- Obtain Third Party Services. We may also share Personal Information with third parties who provide services to ONE Pac, such as web analytics, customer relationship management, event / campaign management, web site management, information technology and related infrastructure provision, payment processing services, fraud monitoring and prevention, customer service, e-mail delivery, auditing, and other similar services. When ONE Pac shares Personal Information with third party service providers, we require that they use your Personal Information only for the purpose of providing services to us and subject to terms consistent with those of this Policy.
- Improve Services, and Experiences. We may use your Personal Information to evaluate and improve our Services, marketing, and customer relationships.
- Post Testimonials. We post testimonials on the ONE Pac Websites that may contain Personal Information. Prior to posting a testimonial, we will obtain your consent to use your name and testimonial. If you wish to update or delete your testimonial, please send an email at firstname.lastname@example.org, and be sure to include your name, testimonial location, and contact information.
- Power Joint Sales, Product Promotions or joint marketing campaigns. ONE Pac and its partners may engage in joint sales, product promotions and joint marketing campaigns. Such promotions may or may not reference the partners involved. Both ONE Pac and the partner(s) will have access to that information, and either ONE Pac or our partners may provide you the sales or product promotion information. Each party will be responsible for managing their own use of the Personal Information collected for the joint sale or product promotion. We recommend you review the privacy policies of these partners to address any questions you have regarding their handling of your information.
- Communicate with You about a Conference or Event. We, our service providers, or our partners may communicate with you about a conference or event hosted or co-sponsored by ONE Pac or one of our partners. This may include information about the event’s content, logistics, payment, updates, and any additional meetings, special demonstrations or other customer facilitation that we may provide related to your event registration. After the event, ONE Pac may contact you about the event and related products and services, and may share information about your attendance with your company. Where legally permitted, ONE Pac will also allow designated partners or conference sponsors to send you communications related to your event attendance. Please note that our partners or conference sponsors may directly request your personal information at their conference booths or presentations. You should review their privacy policies to learn how they use personal information.
- Investigate and respond to any comments or complaints that you may send us. ONE Pac may collect and use your Personal Information for our internal investigation on the comments or complaints that you may send us through different channels.
- Comply with Legal Requirements and Corporate Transactions. ONE Pac may disclose your Personal Information as we believe to be necessary or appropriate: (a) under applicable law, including laws outside your country of residence; (b) to comply with legal process; (c) to respond to requests from public and government authorities, including public and government authorities outside your country of residence; (d) to enforce our terms and conditions; (e) to protect our operations or those of any of our affiliates; (f) to protect our rights, privacy, safety or property, and/or that of our affiliates, you or others; and (g) to allow us to pursue available remedies or limit the damages that we may sustain. Additionally, in the event of a reorganisation, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceedings), we may transfer the Personal Information we have collected to the relevant third party.
Some of the Personal Information uses specified above are not mandatory and may be controlled by you. Please refer to the “Registration, Preferences and Opt Out” section below for information on available use preferences or opt-out options, or view the summary of your privacy choices.
How do we store your Personal Information
Storage and processing. ONE Pac stores your Personal Information and analytics data on ONE Pac servers and the servers of companies we hire to provide services to us. We only retain your Personal Information for so long as it is necessary. Data may be archived as long as the purpose for which the data was used still exists. ONE Pac operates in multiple jurisdictions and we may exchange information internally between our offices and remote worksites. The Personal Information that you have provided to us may therefore be transferred outside the jurisdiction where you reside. Also, in certain countries our third party contractors (such as online application providers) might undertake the collection, transferring, storage and processing of your information on our behalf and control. Such collection, transfer, storage and processing of information will be done in accordance with the terms and conditions of this Policy.
Report of Data Breach Procedures. ONE Pac has proper internal procedures in place on data breach detection, investigation and reporting in compliance with General Data Protection Regulation (GDPR).
Registration, Preferences and, Opt-Out
A list of your current privacy choices is listed below:
Preferences and Opt-Out.
- E-mail Marketing. ONE Pac enables you to opt out of marketing communications. You may opt out of e-mail marketing by using our general unsubscribe automated link that is included in ONE Pac marketing e-mails. If you have any problems using that opt-out mechanism, please send us an email at email@example.com.
Some non-marketing communications are not subject to general opt-out, such as communications related to Services, sales transactions, and other support related information, conferences or events for which you have registered, disclosures to comply with legal requirements, and (where permitted by law) quality assurance surveys. Some additional communications with partners are also not subject to general-opt out, including product alerts, updates, contractual marketing and sales materials, and other notices related to partner status.
- Information-Sharing Choices. ONE Pac only shares Personal Information with selected companies after providing users the ability to make choices about the sharing, or as otherwise described in this Policy. There are limitations to opting out of such sharing in the case of: (1) joint sales or joint events; (2) where the customer has been notified or requested follow-up which involves ONE Pac partners; (3) where third parties are required to accomplish the transaction or perform the service; and (4) where required by law.
- Third Party Permission-Based Lists. On occasion, ONE Pac may use third-party lists to send communications about ONE Pac products and services. These lists, which are maintained by third parties, include users eligible under applicable law to receive e-mails from other companies such as ONE Pac. When we use such lists, the communications will include mechanisms to opt out of receiving ONE Pac marketing communications. If you have trouble opting out, or if you wish to make us aware of any issues related to a third-party mailing, you may contact us directly.
Access and Rectification Request
We take all reasonable precautions to ensure that the Personal Information we collect, use and disclose is accurate, complete and up-to-date. However, the accuracy of that Personal Information depends to a large extent on the Personal Information you provide. You can always request access, inquire about or make corrections to your Personal Information in our possession, by writing to us at: firstname.lastname@example.org .
If we make any material changes to this Policy, we will notify you by email or by posting a prominent notice on the ONE Pac Websites prior to the change becoming effective. We encourage you to periodically review this page for the latest information on our privacy practices. Your continued use of the ONE Pac Service constitutes your agreement to be bound by such changes to this Policy. Your only remedy, if you do not accept the terms of this Policy, is to discontinue use of the ONE Pac Services.
Other Information Sharing
ONE Pac may also share your Personal Information:
- When you agree to the sharing;
- When we are required to provide information in response to a subpoena, court order, or other applicable law or legal process;
- When we have a good faith belief that the disclosure is necessary to prevent or respond to fraud, defend our apps or websites against attacks, or protect the property and safety of ONE Pac, our customers and users, or the public;
- If we merge with or are acquired by another company, sell an ONE Pac product, solution or business unit, or if all or a substantial portion of our assets are acquired by another company, your Personal Information will likely be disclosed to our advisers and any prospective purchaser’s advisers and will be one of the assets that is transferred to the new owner.
If you believe your Personal Information has been used in a way that is not consistent with this Policy, or if you have further questions related to this Policy, please contact our Data Protection Officer with written inquiries at 13/F, 135 Bonham Strand Trade Centre, Bonham Strand Street, Sheung Wan, Hong Kong, or by email, at email@example.com.
Contact the Appropriate Authority
If you have enquiries in regards of Personal Information Data Collection policy in Hong Kong, please contact Privacy Commissioner for Personal Data, Hong Kong at firstname.lastname@example.org