(effective 1st June 2016)
Collection of Customer’s Personal Information
For the purpose of carrying on Compass Offices’ business including sale, provision, registration and advertisements of Compass Offices’ serviced offices and related products and services, Compass Offices will collect your personal information when you:
- enter into an agreement for serviced office space, virtual offices or related services with Compass Offices;
- enquire as to information about a product or service of Compass Offices;
- contact Compass Offices with an enquiry or complaint;
- enter any promotions, competitions, prize draws through Compass Offices’ services;
- use Compass Offices’ products or services;
- take part in market research; or
- visit or browse Compass Offices’ websites.
Types of Personal Data Collected
For the purpose of carrying on Compass Offices’ business including sale, provision, registration and administration of Compass Offices’ serviced office and related products and services, the information that Compass Offices includes but is not limited to the following:
- your name;
- correspondence address and/or billing address;
- account details, including account numbers, service numbers or user accounts;
- payment details including credit card information, bank account and other banking information;
- contact details, including contact name and fixed and mobile telephone and email address;
- your date of birth;
- information for the verification of your identity including identification number;
- your preferences for particular products or services;
- a note or recording of a call that you made to Compass Offices’ hotlines;
- an email or letter that you sent to Compass Offices; and other records of any contact you have with Compass Offices; and
- your account information, such as dates of payment, the services you have subscribed to, and any other information relating to your account.
Use of Customers’ Personal Information
Compass Offices may use and analyse your information for the following purposes including but not limited to:
- for the daily operation of Compass Offices’ services provided to customers;
- conducting credit checks when required;
- designing services or products for customers’ use;
- processing your order and providing the products and services that you have bought from Compass Offices;
- keeping you updated of Compass Offices’ latest offers or promotions;
- marketing the following products and services (in respect of which Compass Offices may or may not be remunerated):
- all products or services by Compass Offices including serviced office space, virtual offices and Internet connectivity;
- reward, loyalty or privileges programmes and related products and services; and
- products and services offered by Compass Offices’ business partners including travel, dining, entertainment, apparel, health & beauty, education, household, transportation, banking, insurance and other products and services.
- assisting you with any products or services enquiries, including investigating and resolving service affecting issues and dealing with any billing enquiries you may have;
- billing you for using Compass Offices’ products or services;
- analyzing usage of Compass Offices’ products and services by you and other customers so that Compass Offices can further improve Compass Offices’ products and services and/or better tailor the type of products and services presented to customers;
- carrying out research and statistical analysis and monitoring customer use of Compass Offices’ products and services on an anonymous or depersonalised basis;
- assisting Compass Offices in fraud or crime prevention;
- debt tracing, debt recovery and credit management; and
- contacting you if necessary.
Retention of Personal Data
Compass Offices will destroy any personal data it may hold in accordance with internal policy. Personal data will only be retained as long as Compass Offices needs it unless the personal data is also retained to satisfy any applicable statutory or contractual obligations or for the purpose of investigation, detection and prosecution of crime.
Disclosure and Sharing of Personal Data
All personal data held by Compass Offices will be kept confidential but Compass Offices may disclose information about you to the following parties:
- companies in the Compass Offices Group;
- contractors, agents and suppliers who are involved in delivering the products and services you have ordered and used;
- any banking or financial institutions, charge or credit card issuing companies;
- credit information or reference bureaus;
- debt-collection agencies or other debt-recovery organizations;
- emergency services;
- professional advisors (including lawyers and auditors);
- any agent, contractor or third party service provider who provides administrative, telecommunications, computer, payment or other services to Compass Offices in connection with the operation of its business;
- law-enforcement or government bodies, regulatory bodies, courts or as required by any applicable law;
- any person to whom Compass Offices is under an obligation to make disclosure under the requirements of any relevant law binding on Compass Offices or under and for the purposes of any guidelines issued by regulatory or other authorities with which Compass Offices is expected to comply;
- third party reward, loyalty and privileges programme providers;
- business partners of Compass Offices;
- external service providers (including but not limited to mailing houses, telemarketing and direct sales agents, call centres, data processing companies and information technology companies) that Compass engages for the purposes set out under the section “Use of Customers’ Personal Information”.
Transfer of Personal Data Outside of the Country in Which the Relevant Centre is Located
At times it may be necessary and/or prudent for Compass Offices to transfer certain personal data to other group companies or service providers outside of the Country in which the relevant centre is located. This may happen if Compass Offices’ servers or suppliers and service providers are based outside of the country of origin or if you use Compass Offices’ services and products while visiting countries outside the country of origin. Compass Offices will endeavour to ensure that your personal information used by such third parties is in accordance with this policy.
Your Privacy Rights
In accordance with the terms of any applicable local laws or relevant ordinances, and subject to the exemptions specified in such laws and ordinances, any customer:
- has the right to check whether Compass Offices holds any personal data about him or her and has a right to receive copies of such data;
- has the right to require Compass Offices to correct any personal data relating to him or her which is inaccurate; and
- has the right to ascertain Compass Offices’ policies and practices in relation to personal data and to be informed of the kind of personal data held by Compass Offices.
In accordance with the terms of any relevant laws or applicable ordinances, Compass Offices is entitled to charge a reasonable fee for processing a data access request.
Requests for access to personal data, correction of personal data, information relating to the kind of data held and to stop receiving or re-commence receiving direct marketing may be made in writing by email or post to:
The Data Protection Officer
Grand Strong Holdings Limited / Compass Offices
Level 21, The Center,
99 Queen’s Road Central,
Central, Hong Kong
Please identify yourself with your name and contact number when writing to the Data Protection Officer.
If there is any inconsistency or conflict between the version posted on the website and previous versions, this version shall prevail. If there is any inconsistency or conflict between the English and Chinese versions of this policy, the English version shall prevail.