Johnny Yuen – Finance Director (HK) and Company Secretary
Tel: +852 2772 0007
Email: ir@ircgroup.com.hk

 

Privacy Policy Statement

IRC Limited (the “Company”) is committed to protecting all Personal Data under our custody, control or possession. We have created this privacy policy to ensure that you understand how your personal data will be used and that you understand your rights under the Personal Data (Privacy) Ordinance, Laws of Hong Kong (Cap 486) (the “PDPO”).

This privacy policy applies to all personal identifiable information about you or from which you are identifiable (“Personal Data”) including data we collect through our website (www.ircgroup.com.hk) or through our other interactions with shareholders of the Company. If you do not agree with this policy, then you should contact us using the details under the section headed “Investor Enquiry” on this page of our website to request us to cease using your personal data. It is important that you read this policy as well as any other personal information collection statements and privacy notices we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of why and how we are using your data. This policy supplements other notices and policies of the Company and is not intended to override them.

Please note that this privacy policy may be amended from time to time without prior notice. If we amend this privacy policy we will post the amended policy on this page, so you are always aware of what information we collect, how we use it and under what circumstances we may disclose it.

Collection of Personal Data

We collect Personal Data if you voluntarily submit it to us.

In particular, we collect Personal Data (such as name, telephone number, mailing or email address) provided by you should you, among others, (i) choose to complete various investor relations process (e.g. completing proxy forms or filling in the reply form/ request form in relation to your choice of language or means of receiving corporate communications) to enable you to attend, participate in, and exercise your shareholder rights during the Company’s shareholder meetings and receive our corporate communications via means elected by you; and (ii) contact us or our Hong Kong share registrar via any of the means provided on the page headed “Contact Us – Investor Enquiry” on our website or any communications we or our Hong Kong share registrar send to our shareholders, investors or to the media.

We also collect Personal Data pursuant to applicable laws and regulations including without limitation the Securities and Futures Ordinance, Laws of Hong Kong (Cap 571) and the Companies Ordinance, Laws of Hong Kong (Cap 622).

We may also retrieve Personal Data from publicly available sources such as: (i) print and digital media; (ii) promotional or other materials relating to you; (iii) websites of entity or organisation with which you are connected; and (iv) government, regulator, or industry registries.

When you visit our website, we will record your visit only and will not collect any Personal Data about you or from which you are identifiable unless otherwise stated. Cookies used (if any) in any part of our website will not be deployed for collecting Personal Data. You may also refuse to accept cookies (by modifying the relevant internet options or browsing preference of your computer system), but to do so, you may not be able to utilise or activate certain available functions in our website.

Main Purposes of Collection

We will use your Personal Data you provide to us, or which we or our Hong Kong Share Registrar, already hold about you, for (i) the purposes set out in this section; (ii) our investor relations and shareholders’ communication purpose; (iii) where you have given your consent in advance for your Personal Data to be processed or used for a different purpose; or (iv) where permitted by law.

If you completed the investor relations process (e.g. completing proxy forms or filling in the reply form/ request form in relation to your choice of language or means of receiving corporate communications), we will use your Personal Data to enable you to participate in the relevant shareholders’ meeting or provide with you with the corporate communications as instructed.

If you contact us or our Hong Kong share registrar via any of the means provided on the page headed “Contact Us – Investor Enquiry” on our website or any communications we send to our shareholders, investors or to the media, we will use your Personal Data to contact you as requested.

We may also compile and store any of the contact information or other Personal Data you provide us with. We may use that information, together with any personal data we or our Hong Kong share registrar already hold about you, in whole or in part when fulfilling any of the purposes described in this privacy policy.

We may also use the personal data you submit where it is necessary for our legitimate interests (including in order to administer and protect (such as troubleshooting, data analysis, system maintenance, etc.)) for our business and our website, including livestreaming, digital meeting formats provided through this website or other digital platforms and channels, to deliver relevant website content to you and to measure or understand the effectiveness of the content of the of our website and the corporate communications we provide to you.

We also reserve the right to access and/or disclose any information where such processing is required by laws and regulations, courts or administrative agencies or is necessary to permit us to investigate suspected fraud, harassment or other violations of any law, rule or regulation.

Data Retention and Security

We will take all practical steps to ensure that personal data will not be kept longer than necessary and that we will comply with all statutory and regulatory requirements concerning the retention of personal data.

We also take appropriate measures to protect the Personal Data against loss, and unauthorised access, use, modification or disclosure.

Access and Correction of Personal Data

You have the right under the PDPO to ascertain whether we hold Personal Data relating to you, to obtain a copy of those data, and to correct any data that is inaccurate. Requests for access and correction should be in writing. Please contact us using the details under the section headed “Investor Enquiry” on this page of our website.

In accordance with the terms of the PDPO, we have the right to charge a reasonable fee for the processing of any data access request.

Data Transfer

Your Personal Data held by us will be kept confidential but we may provide such information:

• to our employees, agents, contractors and other service providers authorised or engaged by the Company or its affiliate who are under a duty of confidentiality to the Company or its affiliates or other contractual terms to safeguard your Personal Data, and who provide administrative, data processing, research and marketing, distribution, telecommunications, professional or other services to the Company or its affiliate, (including the Company’s Hong Kong share registrar, service providers that conduct the registration procedure for and hosting of company webcasts or other live streaming or digital meeting formats, and service providers involved in the distribution of emails and other IT system support and maintenance);
• to our professional advisers who are under a duty of confidentiality to the Company;
• where such disclosure is authorised or required by law, regulations or rules; and
• in response to requests by agency or organisation relating to law enforcement purposes.